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Paul Ferris Comment On Regulatory Notice 22-08

Paul Ferris
N/A

To: FINRA

Re: FINRA Regulatory Notice #22-08

To Whom it May Concern:

I am firmly opposed to any imposed regulations or restrictions of the open market buying and selling of leveraged and inverse investment products.

Investing in inverse products is no different than shorting a stock. Inverse products allow investors to invest in a stock or a segment of the market or a market index that is in decline and make a profit thru its inverse correlation to a stock or index. The NASDAQ, S&P 500 and Dow indexes have been in decline for six months as of this date. Inverse products offer a safe and reasonable way to benefit from these market moves, in the same way that shorting a stock does. I have been utilizing inverse products at the appropriate times for many years, successfully, with no special training.

Leveraged products allow aware investors to take advantage of segments of the market that thru their own research believe that a segment of the market, like semiconductors, energy and many others will be making a sizeable move in the short term. I do my own research, I invest my own money, and I have no special training and need no regulations to keep me safe.

Here's just one example. Thru my own research I became aware the futures prices for natural gas were rising sharply this year. There is an ETF called BOIL that is leveraged to the price of nat gas. BOIL is up 280% YTD as of May 3, 2022. There is no reason why I should be restricted in any way in investing in BOIL, or SOXL, which is leveraged to a semiconductor index. Again, thru my own research and study, I have prospered by making investments in SOXL when semiconductor stocks are on the rise. The decision to invest in these products should be solely up to me.

Please, for the sake of countless small investors like myself, do not impose any regulations or restrictions on the ability to invest in inverse or leveraged products. Let the buyer and only the buyer beware.