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Samuel Mathers Comment On Regulatory Notice 22-08

Samuel Mathers
N/A

Dear FINRA Regulators,

I was upset to learn today that FINRA was looking to restrict retail investor's access to 'complex products' including leveraged products. As a young investor, I rely heavily on leveraged etfs as part of my long term investing strategy. Given my current investable assets are low and will hopefully continue to grow as I work and grow older, I use leveraged products such as 2x S&P 500 etfs to attempt to smooth my exposure to the market throughout my lifetime. For example, say I have $100,000 to invest currently but based off of how much I will be able to save, I expect to have $200,000 in 5 years that I plan to invest in the market. There is no reason why I would want more exposure then as opposed to now. To remedy this, I can invest my 100k in a 2x etf and as my net worth grows, slowly roll my exposure into the vanilla etf when I have 200k, maintaining 200k worth of exposure throughout those 5 years.

If it weren't for leveraged etfs, I would not as easily be able to keep my exposure to the markets constant and hedge away the risk associated with the distribution of returns throughout my lifetime. I and other retail investors understand the risks associated with leveraged products. Education is important but there are so many sources available to educate oneself. Ultimately, I have decided that despite the risks, the benefits of such products make them worth it. And that decision will be unique to each individual investor, and cannot be decided in aggregate by a regulator. Rather than making finance more opaque by restricting retail access to important products that exist for a reason and are used by financial professionals, we should work towards educating investors about the risks and benefits of such products.

The general public is capable of making investing choices on their own as each individual situation needs a unique solution. It is insulting to have my access to products that form integral parts of my long term investing strategy taken away because regulators feel that retail investors need to be baby sat and can't be trusted with their own assets. And ultimately it is counter productive to the goal of empowering everyone to safely plan their financial futures.