Over the years, I have used many of the "complex products" that are the subject of Regulatory Notice 22-08 including leveraged ETPs, inverse ETPs and options. In all cases, I did the appropriate research on these products to understand how they work and the risks associated with using them. These products have been an important part of my investment portfolio to either hedge certain positions or to leverage other positions. In all cases, if I reviewed a complex product and it was unclear to me what it was or how it worked, I simply did not include it in my investment portfolio. I believe strongly that I should be able to invest in any complex product that meets the needs of my investment portfolio. I should not be prevented or restricted in any way from including these products in my portfolio simply because they are complex or too difficult to understand or confusing. If your goal is to protect investors (which I believe is an honorable goal and one that I support), the way to achieve this goal is NOT to put unnecessary restrictions on my ability to purchase or sell complex products. A better way to protect investors (which I strongly support) is to require the companies that offer complex products to provide clear, standardized documentation regarding what the products are and how they work. If it is clear what the products are, then each individual investor can make an informed decision as to whether those products belong in their investment portfolio. In my opinion, this standardized documentation will provide the protection to the individual investor that you are trying to achieve.
Michael Calwas Comment On Regulatory Notice 22-08
Over the years, I have used many of the "complex products" that are the subject of Regulatory Notice 22-08 including leveraged ETPs, inverse ETPs and options. In all cases, I did the appropriate research on these products to understand how they work and the risks associated with using them. These products have been an important part of my investment portfolio to either hedge certain positions or to leverage other positions. In all cases, if I reviewed a complex product and it was unclear to me what it was or how it worked, I simply did not include it in my investment portfolio. I believe strongly that I should be able to invest in any complex product that meets the needs of my investment portfolio. I should not be prevented or restricted in any way from including these products in my portfolio simply because they are complex or too difficult to understand or confusing. If your goal is to protect investors (which I believe is an honorable goal and one that I support), the way to achieve this goal is NOT to put unnecessary restrictions on my ability to purchase or sell complex products. A better way to protect investors (which I strongly support) is to require the companies that offer complex products to provide clear, standardized documentation regarding what the products are and how they work. If it is clear what the products are, then each individual investor can make an informed decision as to whether those products belong in their investment portfolio. In my opinion, this standardized documentation will provide the protection to the individual investor that you are trying to achieve.