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John Logan Comment On Regulatory Notice 22-08

John Logan
N/A

I invest and trade in my Roth IRA account. The IRS prohibits any short positions in an IRA thus eliminating any opportunity of arbitrage except by using inverse mutual funds. Prohibiting investment in leveraged or inverse funds would cause investors like me great harm. I believe that I understand them well enough to avoid common pitfalls. In years past I held Series 6, 7 and 24 licenses and for a while served as president of a bank-related brokerage firm. To make such a move as you are contemplating, you need to first show that great harm is occurring in a significant segment portion of the investing public by their use. I don't believe that to be the case.