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Lemuel Anaejionu Comment On Regulatory Notice 22-08

Lemuel Anaejionu
N/A

To Whom It May Concern:

Your recent notice, FINRA Regulatory Notice #22-08, seems very problematic for everyday investors. Leveraged and/or Inverse funds serve very important functions for retail public investors. Most of the time, they provide the only way for a retail investor to cost effectively hedge a position or a certain exposure. For example, earlier this year my wife and I were waiting to close on a new house. Unfortunately, the Builder kept extending the closing date and we were unable to lock the loan rate without this date. Given that interest rates were rising, this was a huge financial exposure for my family. After a little bit of research, I found TBT (ProShares UltraShort 20+ Year Treasury). With a combination of a direct investment in TBT and certain derivative investments connected to TBT, I was able to more than offset the cost of the increased loan points in order to preserve the lower interest rates for my loan. We ended up closing our house purchase with a very desirable interest rate.

As an update to this story: after we closed on our house, I have continued to maintain these positions, and they are my best performing positions YTD in 2022.

I encourage you to reconsider your proposed position on "Complex Products." Especially as we enter into an economic downturn where inverse funds may be a key investment strategy of a retail investor like me.

Thank you for your consideration.