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Mark Reisler Comment On Regulatory Notice 22-08

Mark Reisler
N/A

I oppose restrictions on my right to invest in vehicles that are of my own choosing, and I do not believe FINRA should be able to dictate to me about the use of my own money. I am capable of understanding public investment vehicles and I should not have to pass some sort of test in order to invest in them. Inverse funds play an important role for me to be able to hedge other long investments, and I should not have to generate a significant number of transactions (i.e. sell many long positions) in order to adjust my overall risk. This is a critical point for me - markets can be subject to significant drawdowns and inverse funds help me protect my portfolio. I was able to weather the 2008-2009 market crash due in part to use of inverse funds. I also use small positions in leveraged funds to enhance my overall portfolio performance, particularly when there is an overall positive trend in motion. Use of inverse or leveraged funds constitute only a limited part of my overall portfolio, yet provide a significant part of my overall investment strategy.