I am writing this comment about the "Regulatory Notice 22-08". In short, this notice pertain to what FINRA considers as a "complex product".
As goes with almost everything the "complexity" is in the eyes of the beholders. What's complex for one might be simple for another. Therefore, I believe, imposing someone's idea of what's complex and what's not on someone else, is unwise and uncalled for.
<< A machinery like "internal-combustion-engine" and a "spark-plug" might be considered complex, yet significant number of Americans use this machinery for driving every day. An encoding like "MP4" and "FLV" might be considered complex, yet significant number of Americans use this encoding for entertainment every day. >>
In a capitalistic country like the USA, full disclosure of a financial product is ought to be made - which is done extensively via prospectus - and after the full disclosure, the decision of whether to use or not use the financial product ought to be left to the person without any overarching regulation.
Any regulation that limits the usage of any fully disclosed product - such as a leveraged mutual fund, or an inverse mutual fund, or a leveraged ETF or an inverse ETF or a Crypto Currency based mutual fund, or a Crypto Currency based ETF will be unsuitable for a capitalistic free country like the USA.
<< If a communist country like China bans Crypto and whatever else, then perhaps it's all right. If a regulator were to do this sort of ban, in a free CAPITALISTIC democracy like USA, then that will be quite an unwelcome change. In short it will be un-American. >>
I am an individual trader, and I have significant amount of my time developing/perfecting my tactics/strategies of trading Leveraged/Inverse mutual funds, and ETFs. I have perfected my tactics/strategies for Crypto based mutual funds, trusts and ETFs as well.
Salil Gangal Comment On Regulatory Notice 22-08
Hello,
I am writing this comment about the "Regulatory Notice 22-08". In short, this notice pertain to what FINRA considers as a "complex product".
As goes with almost everything the "complexity" is in the eyes of the beholders. What's complex for one might be simple for another. Therefore, I believe, imposing someone's idea of what's complex and what's not on someone else, is unwise and uncalled for.
<< A machinery like "internal-combustion-engine" and a "spark-plug" might be considered complex, yet significant number of Americans use this machinery for driving every day. An encoding like "MP4" and "FLV" might be considered complex, yet significant number of Americans use this encoding for entertainment every day. >>
In a capitalistic country like the USA, full disclosure of a financial product is ought to be made - which is done extensively via prospectus - and after the full disclosure, the decision of whether to use or not use the financial product ought to be left to the person without any overarching regulation.
Any regulation that limits the usage of any fully disclosed product - such as a leveraged mutual fund, or an inverse mutual fund, or a leveraged ETF or an inverse ETF or a Crypto Currency based mutual fund, or a Crypto Currency based ETF will be unsuitable for a capitalistic free country like the USA.
<< If a communist country like China bans Crypto and whatever else, then perhaps it's all right. If a regulator were to do this sort of ban, in a free CAPITALISTIC democracy like USA, then that will be quite an unwelcome change. In short it will be un-American. >>
I am an individual trader, and I have significant amount of my time developing/perfecting my tactics/strategies of trading Leveraged/Inverse mutual funds, and ETFs. I have perfected my tactics/strategies for Crypto based mutual funds, trusts and ETFs as well.
Some of my techniques are documented for public usage:
(1) http://salilgangal.com/info/trading_algo_blitz.html
(2) http://salilgangal.com/info/trading_algo_fluctuation.html
(3) http://salilgangal.com/info/crypto_API_order_entry.html
As you can surmise, significant time/effort hasd been put into this.
I strongly urge FINRA to not pass any regulation that would limit my usage of leveraged/inverse/crypto products.
Thanks.
~ Salil