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Robert Stefancik Comment On Regulatory Notice 22-08

Robert Stefancik
N/A

As an individual investor I consider
leveraged and inverse investment funds very useful to manage risk in my overall investment portfolio. They represent a minority but important percentage of my overall portfolio and are utilized to help offset and mitigate risk in my more Substantial longer term positions on a short term basis, avoiding disruptive transactions in my long term holdings.

I am quite capable of comprehending the usefulness and potential risks associated with the funds and dont think it is necessary to undergo imposing hurdles and special qualifications to constructively manage my portfolio.

If restricted from using the funds I could be forced to engage more expensive alternatives such as third party investment advisors that would charge fees at my expense that would reduce my net returns on my portfolio.

I have a considerable sized portfolio but not of the magnitude that the most privileged investors that have the advantage of access to more favorable and complex financial instruments and hedging strategies.

The basis of how these leveraged and inverse funds are readily disclosed up front in my brokerage firms trading platform prior to engaging in a trade and are easily understood.
I think it would be a disservice to investors such as me to impose any further restrictions on engaging in these most useful transactions that help protect my investments.