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Richard Goldschmidt Comment On Regulatory Notice 22-08

Richard Goldschmidt
N/A

I am concerned that FINRA wants to impose restrictions on access to investment vehicles that are useful and valuable to many investors. I believe it would be a mistake to impose restrictions on the availability of one small class of investment vehicles when comparable vehicles are available without the same restrictions. Leveraged ETFs are comparable to the use of margin for example, which is widely available. I think it may be helpful to recommend that brokers provide a notice that states clearly that such leveraged investments are more risky because of the use of leverage. But I strongly oppose significant restrictions on the availability of these kinds of investment vehicles. Customers will simply find ways around these restrictions, and might for example, find their way to products not regulated by FINRA, like futures and futures options. Why would you want to drive business to other markets, and away from the brokers you serve? Give a simple warning and let people make their own decisions about risk taking.