To Whom It May Concern:
I retired just over a year ago. I had no pension at work nor any other sponsored retirement plan. I had my own investments in both IRAs and non-qualified accounts. My life has not been easy because of divorce and child custody battles, bad economies over the last 20 years, a relatively low income (mostly in the $50-$60 range) and living in high cost of living areas, such as New York, New Jersey and Maine where the personal income tax is about a flat 8%. If it were not for the investments that you are now considering as improper for people who do not pass a regulator-imposed test of specialized investment knowledge, demonstrate a high net worth, get special approval from a broker, attest to reading certain materials, and go through a cooling off periods during which you cant invest, I would not have been able to retire.
These investments, in my opinion, represent a lower risk than many other investments that require no such restrictions on the investor. As an example, looking back at the mortgage market in the early 2000s will demonstrate that this widely used investment (the purchase of a home), was and still is poorly understood by the investor. Also, the generally available investments in specialized mutual funds, such as China funds, Asian funds, etc., is an extremely high-risk investment. Russian based mutual funds have become a disaster.
In the investment world today, trades are made by computers using algorithms which cause a trade in nano seconds. The need to get special approval from a broker or have a cooling off period gives us regular guys a considerable disadvantage in an arena where we already have a disadvantage. These new regulations will build in another high, nearly insurmountable wall to overcome and create a Catch 22 for people like me, who do not have a high net worth. We regular people with low net worth will not be able to use the investment tools that will allow us to more easily obtain a higher net worth if these new protocols are put into place.
It is widely accepted that index funds (based upon the S&P 500, DJI, Russel 3000) are one of the safest investments one can make. These funds generally outperform the regular persons stock picks as well as the brokers stock choices. After adjusting for inflation the market returns have been (to 2020) 11.95% for 5 years, 5.3% for 20 years and 8.29% for 30 years. On average, the stock market has returned roughly 10% per year. This can vary widely each year depending on a variety of market factors (U.S. Securities and Exchange Commission Savings and Investing Page 14). Everyone should have free access to a fund that is leveraged two or three times and because of the nature of these investments, if the value goes down, there is no margin call and no need to come up with more cash, as there is with buying more stocks using margin leverage. The investments you wish to make more difficult for people like me, are safer than broker assisted purchases in this instance.
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Jon Greenberg Comment On Regulatory Notice 22-08
To Whom It May Concern:
I retired just over a year ago. I had no pension at work nor any other sponsored retirement plan. I had my own investments in both IRAs and non-qualified accounts. My life has not been easy because of divorce and child custody battles, bad economies over the last 20 years, a relatively low income (mostly in the $50-$60 range) and living in high cost of living areas, such as New York, New Jersey and Maine where the personal income tax is about a flat 8%. If it were not for the investments that you are now considering as improper for people who do not pass a regulator-imposed test of specialized investment knowledge, demonstrate a high net worth, get special approval from a broker, attest to reading certain materials, and go through a cooling off periods during which you cant invest, I would not have been able to retire.
These investments, in my opinion, represent a lower risk than many other investments that require no such restrictions on the investor. As an example, looking back at the mortgage market in the early 2000s will demonstrate that this widely used investment (the purchase of a home), was and still is poorly understood by the investor. Also, the generally available investments in specialized mutual funds, such as China funds, Asian funds, etc., is an extremely high-risk investment. Russian based mutual funds have become a disaster.
In the investment world today, trades are made by computers using algorithms which cause a trade in nano seconds. The need to get special approval from a broker or have a cooling off period gives us regular guys a considerable disadvantage in an arena where we already have a disadvantage. These new regulations will build in another high, nearly insurmountable wall to overcome and create a Catch 22 for people like me, who do not have a high net worth. We regular people with low net worth will not be able to use the investment tools that will allow us to more easily obtain a higher net worth if these new protocols are put into place.
It is widely accepted that index funds (based upon the S&P 500, DJI, Russel 3000) are one of the safest investments one can make. These funds generally outperform the regular persons stock picks as well as the brokers stock choices. After adjusting for inflation the market returns have been (to 2020) 11.95% for 5 years, 5.3% for 20 years and 8.29% for 30 years. On average, the stock market has returned roughly 10% per year. This can vary widely each year depending on a variety of market factors (U.S. Securities and Exchange Commission Savings and Investing Page 14). Everyone should have free access to a fund that is leveraged two or three times and because of the nature of these investments, if the value goes down, there is no margin call and no need to come up with more cash, as there is with buying more stocks using margin leverage. The investments you wish to make more difficult for people like me, are safer than broker assisted purchases in this instance.