It is an investors right to freely access the entirety of the public securities markets without arbitrary restrictions.
FINRAs scheme is misguided because it:
Hurts Investors: It could potentially deny me the freedom to choose investments that could help me achieve long-term financial security.
Is Arbitrary and Unworkable: FINRAs definition of complex products is so broad, arbitrary and vague that it could ensnare a vast number of commonly used public securities. Tests or criteria to determine investor understanding are subjective and could lead to unfair or even discriminatory treatment of investors.
Upends Our Regulatory System: Under the long-standing disclosure-based system, investors have the right to decide which public equities, bonds and funds they want to buy. The FINRA plan upends that principle, giving regulatorsnot methe power to decide what public securities I can and cannot invest in.
Vineet Jain Comment On Regulatory Notice 22-08
It is an investors right to freely access the entirety of the public securities markets without arbitrary restrictions.
FINRAs scheme is misguided because it:
Hurts Investors: It could potentially deny me the freedom to choose investments that could help me achieve long-term financial security.
Is Arbitrary and Unworkable: FINRAs definition of complex products is so broad, arbitrary and vague that it could ensnare a vast number of commonly used public securities. Tests or criteria to determine investor understanding are subjective and could lead to unfair or even discriminatory treatment of investors.
Upends Our Regulatory System: Under the long-standing disclosure-based system, investors have the right to decide which public equities, bonds and funds they want to buy. The FINRA plan upends that principle, giving regulatorsnot methe power to decide what public securities I can and cannot invest in.