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Michael Hudachek Comment On Regulatory Notice 22-08

Michael Hudachek
N/A

Comments: I am a long time investor of L&I products. For 20 years I have used these products to successfully grow my portfolio. In 2008, after having done extensive research on the impending undermining of off balance sheet investments done by banks with mortgage securities, I successfully grew my portfolio, in spite of the professional advice given by traditional brokers. I specifically used an inverse, leveraged etf to do this. While managing this, I understood the importance of the instruments being linked to that days trading, so it was critical to constantly monitor the market to ensure it was headed in the right direction. I also did this in the opposite direction from 2009 to 2021, switching from inverse to growth ETFs. Recently after understanding the timing of Shillers PE, Jeremy Granthams market assessment and the Feds decision to tighten its balance sheet and raise rates, I switched back to inverse in 2022. Again using L&Is to dramatically increase the value of my portfolio. I am extremely concerned that a government agency with only oversight of the investment community but with little expertise in actual investment would seek to restrict my freedom to invest my hard fought for capital in a manner they believe is best for me. Too many times I have witnessed a turn in the investment climate when traditional investment advisors and government bureaucracies have advocated to stick it out, while the bottom falls out of the market. It is especially important during times such as these, when the market is shifting that investors be allowed the freedom to trust themselves and not be forced to follow a bureaucratic rule. Rules do not consider the fluid environment in which successful investing thrives. Schwab does a great job explaining the risks of these instruments and after 20 years I have a strong understanding myself. I dont need another government agency, who I have no trust in, limiting my ability to grow my capital for my family. Essentially, you would preventing the small investor from having access to the same tools large hedge funds utilize to grow their rich members portfolios. How could anyone consider that to be fair ?