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Reilly Gardner Comment On Regulatory Notice 22-08

Reilly Gardner
N/A

This proposal is an egregious regulatory overstep on the part of FINRA.
a) This is antithetical to American values of freedom and equality. Letting some access these products while presumptuously assuming that those without multi-millions don't have the knowledge or sophistication to use these products is incorrect and frankly and embarrassing stance for FINRA to take.

b) Complex and differentiated products can allow for better diversification and better risk adjusted returns. To restrict the use of these products LITERALLY puts many retail investors at a strategic and mechanical disadvantage. As if this discrepancy between retail and institutional resources wasn't already big enough...you want to go do something that would exacerbate the issue? This is the EXACT OPPOSITE of what FINRA should be doing to help promote equality, security, and education of retail investors.

c) If someone wants to blow themselves up trading then thats their prerogative. I understand trying to insulate investors from potential scams or other malicious pitfalls, but a 3x inverse QQQ ETF is not that. It's a useful tool that EVERYONE should have access to. Nobody at HomeDepo makes sure you know how to use a skillsaw before you buy one....but we all know their obviously dangerous. Same with financial products. If some people don't understand the risk then maybe there should be better documentation or training but removing access is NOT the answer.

d) This general concept behind accredited investors is absurd and antiquated. I know for a fact that I know 10x more than 90% of the population who could qualify as an accredited investor. It's a terrible test of competency and needs to go. If I want to invest in private markets then I should be able to.