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Roger Thomas Comment On Regulatory Notice 22-08

Roger Thomas
N/A

I consider investing my own money a decision that I am fully capable of making without additional controls. The changes being considered to gate who has access to leveraged and inverse ETFs/Funds are barriers to entry. Personally, I use them in my investing to better manage market downturns and to gain better returns. In 2020 when the market was getting hammered, I was able to invest in an inverse ETF which significantly protected my down side. More recently, I was able to invest in a leveraged ETF which brought me significant returns.

If this new regulation is allowed to go through, the outcome is that it will have the impact you are trying to prevent. Investors will not have a place to move their funds during market downturns or it will significantly delay (due to the test etc) their ability to react, which will hurt. I urge you to reconsider this decision, and allow individual investors to continue to manage their own funds without additional controls.

BTW the brokerage service I use already does a great job of alerting prior to investing in these type of investments. Perhaps it could be as simple of ensuring brokerage firms do their part in informing without regulating.