Comments: To whom it may concern: I am writing to provide input concerning the issue of FINRA proposed rules to limit access to leveraged and inverse ETFs and "complex products". I use leveraged and inverse ETFs regularly as a hedge against market volatility. This has been a very valuable and successful tool for me. I fully understand that uneducated investors may use them incorrectly and experience adverse results. So I absolutely agree that they need to be cautioned. My brokerage is Fidelity. When I opened my account(s) with them I went through a process of risk assessment with the goal of determining what strategies and investment vehicles I used. One area they advised me on was options, futures, and leveraged ETFs. At the conclusion of this process I had to sign a form confirming that I had been advised of the risk involved in certain types of investments. I think that for any investor this is an excellent way of advising caution. The first step in education, if you will. Today as I invest in these products I get a caution on my screen, before I enter the order, as a reminder that I am about to invest in an instrument of higher risk. I think this is good. The only thing I would add is a check box that they must click to confirm the investor has read and understood this caution before they can proceed to enter the order. To me this is certainly an adequate system of providing caution for investors. I am concerned about overregulation specifically that puts limits and/or restrictions on my ability to invest in my family's future. I am all for and appreciate education, but not overregulation.
Wayne Korsberg Comment On Regulatory Notice 22-08
Comments: To whom it may concern: I am writing to provide input concerning the issue of FINRA proposed rules to limit access to leveraged and inverse ETFs and "complex products". I use leveraged and inverse ETFs regularly as a hedge against market volatility. This has been a very valuable and successful tool for me. I fully understand that uneducated investors may use them incorrectly and experience adverse results. So I absolutely agree that they need to be cautioned. My brokerage is Fidelity. When I opened my account(s) with them I went through a process of risk assessment with the goal of determining what strategies and investment vehicles I used. One area they advised me on was options, futures, and leveraged ETFs. At the conclusion of this process I had to sign a form confirming that I had been advised of the risk involved in certain types of investments. I think that for any investor this is an excellent way of advising caution. The first step in education, if you will. Today as I invest in these products I get a caution on my screen, before I enter the order, as a reminder that I am about to invest in an instrument of higher risk. I think this is good. The only thing I would add is a check box that they must click to confirm the investor has read and understood this caution before they can proceed to enter the order. To me this is certainly an adequate system of providing caution for investors. I am concerned about overregulation specifically that puts limits and/or restrictions on my ability to invest in my family's future. I am all for and appreciate education, but not overregulation.