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Roy Johnson Comment On Regulatory Notice 22-08

Roy Johnson
N/A

I use double and triple leveraged long and short index funds as one of multiple tools to implement my investment objectives. I invest a small percentage of my investment portfolio in leveraged assets. These leveraged investments achieve a small dumbbell portfolio distribution in what is predominantly a conservative porfolio.

I am a high net worth investor and require special permission to invest in leveraged index funds on my investment platform which includes review of applicable material.

I believe that the current safeguards are sufficient to protect me while not interfering with my ability to continue successfully using leveraged instruments.

I believe that mandating an exam will be a boon to the test prep industry while adding little protection for me.

I am especially concerned about how a "cooling off period" provision would limit my continued ability to use leveraged index instruments.