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Mitchell Gamache Comment On Regulatory Notice 22-08

Mitchell Gamache
N/A

I am strongly opposed to the restrictions proposed by FINRA.

Leveraged and inverse funds are an important strategy and one of the few instruments available that allow retail investors to hedge and/or protect their portfolios and assets. Current market conditions are a prime example of the benefits of leveraged funds, wherein certain aspects of my portfolio have gained in value due over the past month, while the S&P 500 has declined more than 10%. This is due to my ability to utilize inverse leveraged funds as protection against such events.

I am capable of understanding leveraged and inverse funds and their performance characteristics and don't believe that a third-party should be arbitrarily evaluating my capability to do so, potentially preventing my ability to protect my investments or seek enhanced returns if I choose to do so.

The US has a long-standing history of public markets where investors have the freedom to buy public securities without additional government-imposed limitations on my investment choices.