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Jason Munoz Comment On Regulatory Notice 22-08

Jason Munoz
N/A

This comment is to urgently oppose new regulations on so-called "complex products." As an investor with over a decade of experience, I am neither a professional, nor a novice. But the notion of regulating leveraged and inverse products is nonsensical. These products are far and away the easiest to understand of any ETFs/ETNs available to retail investors.

A "complex product" is really just picking a market direction and pace. That's it.

On the flip side, trying to understand the fundamental and technical metrics that value a company is a far more complex endeavor.

Veteran investment professionals with high-level training and experience can and do debate whether or not a stock is a "buy" or a "sell". The complexities going into that analysis can be much more subjective compared to whether you believe the market will, in general, go up or down.

Do not take away inverse products. Investors will be replace their use with options and short selling, which are far more complex and risky.

You either have to let investors take inherent risk, or prohibit everybody from access to the stock market. Which would be an egregious overreach.

Please stick to preventing companies from unfairly and unexpectedly redeeming shares. That is the true problem with retail investing and seems to escape the attention of FINRA.