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Jeff Morrow Comment On Regulatory Notice 22-08

Jeff Morrow
N/A

RE: Restrictions on Leveraged and Inverse ETFs

We know that these investment vehicles are legal, so restricting access is basically unethical and corrupt. If these investment vehicles are open to some, then they should be open to all. The proposal includes language about needing to pass a FINRA exam to invest. Scarry Part is the fact that other investment vehicles could become restricted as well, and then what is the litmus test to buy those products. The question is will government make investors pass a Biochemistry exam to trade IPO Pharmaceutical Companies having only a Phase 3 Clinical Trial Drug. These drugs are very complexed and have high failure rate and a FINRA exam is not going to tell you that but understanding the molecular structures may advise you to invest or not. I could continue and say you need to pass a Professional Engineering exam to by aviation stocks or pass the CPA exam to by banking stocks. The bottom line if you are investing you need to educate yourself. I have had more financial success reaching out and listening to people from all walks of life, than listening to financial advisors. I studied the principles of these leverage vehicles, understand their objectives and allocating some portion of these vehicles make sense for my situation. Let people make these decisions for their own situation.

Another focus is the SEC itself. Investor (with or without a FIRNA Exam) bought GE stock in 2017 and poor leadership at the time cooked-the-books and the stock went from +/- $225 a share to +/-$50 in less than a year. Where was the SEC in this situation, why with all the SEC regulations was this not prevented? More regulation that will help - sarcasm. The point being, more people will and have lost more money with SEC not doing their job, than these Leveraged and Inverse investment options will.

I think we all can safely say, if someone was given $10K to either go to a casino, play the lottery, or invest in a leveraged investment, we would all advise them to invest in these leverage investments. Maybe the SEC should work with the gaming commission and have people take an advanced statistical exam before they can make a wager or buy a lottery ticket (ironically, government runs lotteries).

If these investment vehicles are legal then they should be open to all. Yes, will written perspectives should be available to investors so they can make their own decisions. We cannot police people going to the casino or taking high risks approaches, and nor should we try to police them. If the SEC would focus their efforts on properly reviewing and investigating the GEs, ENRONs, WorldComs, Aldelphias, Madoff and others that would be much more valuable to the investment community.

The biggest and final question: who is really pushing the SEC to do THIS? Someone is having regulations put in so they can profit, while others cannot, this is truly unethical and corrupt. If these investments are so bad, then no one should be able to invest in them. Let people make their own decisions, period!