Skip to main content

Jonathan Kellerman Comment On Regulatory Notice 22-08

Jonathan Kellerman
N/A

Dear Regulators,

I should be able to make my own investment decisions in publicly traded assets based on my understanding of the risks involved in leveraged, Covered Call, inverse, and non K1 commodity funds without the burden of passing additional tests and the elitist nonsense of minimum asset amounts. My traditional "conservative" stock/bond mix portfolios have all dropped over the past 6 months based up on the expected effect of going from QE and unnaturally low long term treasury bond rates and understanding how QT and rate hikes will impact stock and bond values. That stands in contrast to my IRA, which thanks to the ability to hedge this risk with a 3x inverted treasury bond fund, I was able to use about 8% of that portfolio, to have the effect of around 20% inverted treasury bills. This allowed me to offset my losses in my 5 year growth stock plays, and maintain my IRA value. I also invest in an income fund that takes advantage of ETNs, and a 3x leveraged healthcare fund as it is the lowest volatility S&P 500 sector outside of consumer staples with above average returns (turns out when you have an inelastic good, you can keep raising your prices at 5% a year, this is me investing in that lobbyists will continue to make the American health market neither price transparent or price efficient). I have no intention of ever letting any of these leverage and "complex" portions of my portfolio exceeding 30 percent of my IRA retirement account which currently is only 1/3 of total retirement assets, and yes I understand the potential risk of volatility decay, tracking error, daily reseting, and tax implications if used outside my IRA portfolio. I also understand a 33% drop in one day would result in a complete loss. Although I suspect the trading circuit breakers would make that extremely difficult to accomplish. I have sold off my triple inverted bonds over the past several months as the bond market has slid, and look to exit a long term treasury stake once 30 year treasuries hit 3.5-4.5 percent. I also invested in Carbon Credits because either the price 2x
s in Europe, 5x in California, and 10x's in the Northeast, or we all roast. The californian case also has a price floor which goes up at 5% + inflation every year by regulation, which I read. All of these investment decisions in complex products are critical to my overall investment strategy to hedge against QT, inflation, and climate change that will not be stopped because of the inaction of government (I also own a timber etf to hedge floods, fires, tornados and hurricanes, and the general apathy of old people to try and stop them). All of these investments are based on my own research on the internet with either primary sources such as fed notes, climate reports, macroeconomic and business cycle understanding of economics, which I have earned through my own work. These financial decisions and investment decisions should be mine and mine alone, and not made for me in some stuffy board room filled with a bunch of ivy league legacies who are trying to protect their own self interest and hedge fund firms from competition from individual investors with a shrewder sense of the market. To quote Greg Smith, the person who quit Goldman Sachs based on the morally repugnant behavior he saw. To put the problem in the simplest terms, the interests of the client continue to be sidelined in the way the firm operates and thinks about making money." I do not need to pass a test or have a million dollars to represent my own interest and make my own decisions about how to invest.