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Steven Peshek Comment On Regulatory Notice 22-08

Steven Peshek
N/A

Leveraged and Inverse funds play an important role in managing my clients aum. I use them to hedge in down markets like the one we are currently experiencing. I understand their role in an overall investment approach. I use these funds only under specific circumstances and only with high networth clients.

I need these alternatives in order to provide the most complete range of services to help my clients meet their financial goals. If they weren't available, there are not enough alternatives. Itd be like standing in front of a freight train with no way to get off the tracks.

This issue is important enough for me to create the time to address it with you. As President of my single member LLC my time is at a premium. To require burdensome layers of criteria to utilize these funds would be onerous.