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John Bruhl Comment On Regulatory Notice 22-08

John Bruhl
N/A

Please allow me to add to the avalanche of opposition to FINRA Notice 22-08.

I have been using mutual funds and ETFs , that you refer to as "complex products," for many years. When researching any of them on the WebSites of my brokerages, the first thing that appears is an entire warning paragraph in a large, bold font, beginning: "Not suitable for most investors........" The warning goes on to summarize the risks and usually advises against holding the investment longer than a day. In effect, the warning declares that they are only suitable for traders, not investors. The fund prospectus repeats the same thing in excruciating detail.

In general, I choose investments that have demonstrated a history of superior returns over multiple periods: (Year-to-Date, 1 year, 3 years, 5 years, 10 years, 15 years). Surprise, surprise: Many of these "complex products" are among the best performers over all of these periods. This would appear to run counter to the dire warnings not to invest or hold long-term.

Finally, I cannot object strongly enough to your proposal that I be required to prove myself worthy of the right to invest in these products. The last I heard, this was a Free Country where all people, including investors, have the right to make free choices and live with the consequences. As a famous politician one put it: "Please stop helping us."