Individual investors are more educated and have more educational resources than ever. I dont see that there is a need to limit individual investors in a way that is a step back for flexibility and individual choice. Limiting individuals in a significant manner as proposed simply creates a potential monopoly for registered financial advisors to offer services that an individual simply cant have access to on their own. Pricing of various sophisticated financial products has never been more competitive (better) for the individual. This would take a step back in its current form. For brokers, it also is an undo burden to fully vest the specifics of all types of investors beyond what they do already today. In my experience brokers do a good job of KYC (know your customer) already and already have many in house rules, disclaimers, and educational resources in place. If consistency in the education is a major concern perhaps this regulation could be amended to simply require the exact same notice and access to the same educational link hosted to an SEC site explaining more sophisticated financial products in addition to the in house resources and notices already implemented. Having the SEC maintain the standard notice and link would also minimize costs to brokers coming up with their own concepts and may even lead to further reduction in costs for investors (positive).
Patrick Lehner Comment On Regulatory Notice 22-08
Individual investors are more educated and have more educational resources than ever. I dont see that there is a need to limit individual investors in a way that is a step back for flexibility and individual choice. Limiting individuals in a significant manner as proposed simply creates a potential monopoly for registered financial advisors to offer services that an individual simply cant have access to on their own. Pricing of various sophisticated financial products has never been more competitive (better) for the individual. This would take a step back in its current form. For brokers, it also is an undo burden to fully vest the specifics of all types of investors beyond what they do already today. In my experience brokers do a good job of KYC (know your customer) already and already have many in house rules, disclaimers, and educational resources in place. If consistency in the education is a major concern perhaps this regulation could be amended to simply require the exact same notice and access to the same educational link hosted to an SEC site explaining more sophisticated financial products in addition to the in house resources and notices already implemented. Having the SEC maintain the standard notice and link would also minimize costs to brokers coming up with their own concepts and may even lead to further reduction in costs for investors (positive).