Comments: Dear FINRA, I fully understand the composition and risks associated with complex leveraged funds. They are short term in nature and utilize complex derivatives, mostly swaps which may or may not be regulated by public markets. They are an excellent way of maximizing short-term returns when identifying a correct short-term trend in a particular market sector. After voicing concern many years ago about the impact of potentially having private derivatives affecting public companies, my concerns were ignored by both the SEC and PCAOB at the time. As such, I started investing in these vehicles to generate returns that are currently beating the market average. As I'm well aware of how these funds operate and I believe I qualify as a high net worth individual I do not believe it is appropriate to restrict my ability to trade in these funds nor should any investment oversight committee be able to unwind these funds which were started back in 2008 with TECL and were approved by security regulators trading on regulated exchanges. I have no issue with you restricting access to crypto based funds as they are considered an intangible asset by the FASB and SEC indicating they have no substantive value. Please feel free to reach out to me if you have any questions. Thanks.
Keir Majarrez Comment On Regulatory Notice 22-08
Comments: Dear FINRA, I fully understand the composition and risks associated with complex leveraged funds. They are short term in nature and utilize complex derivatives, mostly swaps which may or may not be regulated by public markets. They are an excellent way of maximizing short-term returns when identifying a correct short-term trend in a particular market sector. After voicing concern many years ago about the impact of potentially having private derivatives affecting public companies, my concerns were ignored by both the SEC and PCAOB at the time. As such, I started investing in these vehicles to generate returns that are currently beating the market average. As I'm well aware of how these funds operate and I believe I qualify as a high net worth individual I do not believe it is appropriate to restrict my ability to trade in these funds nor should any investment oversight committee be able to unwind these funds which were started back in 2008 with TECL and were approved by security regulators trading on regulated exchanges. I have no issue with you restricting access to crypto based funds as they are considered an intangible asset by the FASB and SEC indicating they have no substantive value. Please feel free to reach out to me if you have any questions. Thanks.