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James Black Comment On Regulatory Notice 22-08

James Black
N/A

I'm writing to register my concern over and strong opposition to proposed FINRA regulations forbidding average citizens from investing in leveraged and inversely correlated mutual funds.

Removing access to such funds will severely restrict the strategies I have used, for years, to hedge my securities portfolio and insure against economic downturns. These tools have allowed me to smooth my portfolio returns, over the long term, and eliminating my access to them will expose my portfolio to greater, not lesser, risk.

Requiring individual investors, such as myself, to pass federally mandated exams to justify our access to these proven investment vehicles is condescending, in the extreme, and will only serve to provide very large, corporate investors a substantial advantage over smaller, independent investors, who will be discouraged from pursuing leveraged and inverse funds, by fees and general costs of proposed exams. I am not stupid, and I fully understand the risks associated with inverse and leveraged mutual funds. I entered this form of investing with my eyes wide open and was never pressured into employing these vehicles for my own portfolio.

Therefore, I STRONGLY OPPOSE the proposed restrictions on small investor access to Inverse and Leveraged Mutual Funds. Thank you for your patient consideration.