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William Martin Comment On Regulatory Notice 22-08

William Martin
N/A

I strongly disagree with the regulations on leveraged products that FINRA is proposing. As a retail investor, I should be able to choose my investments and make decisions as to what is right for me and my family, without having to go through some special process, be it passing tests, or meeting some net worth that only privileges those with higher net worths.. who are already advantaged with leveraged products in the first place. I also feel that there are already ample warnings from brokerages (like Fidelity), as well as online resources everywhere that abundantly lay out warnings and downsides to leveraged products. Leveraged ETFs are a key part of my investment strategy. Since I am not a high net worth individual, it is critical to my investing strategy that I am able to take on additional leverage to increase my CAGR in the long term leading up to my retirement, to allow compounding interest do its work. I use UPRO + TMF in concert with quarterly rebalancing, following modern portfolio theory to invest in both stocks and bonds, but increase my leverage in order to outperform the S&P 500 in the long term. I am quite capable of holding for the long term, and continuing to invest in these regardless of how far they may fall. The last thing I want is to suddenly get liquidated due to FINRA's regulations passing, or find increased hurdles that prevent or delay me from continuing to invest. Lastly, the money that I invest is my own money. Therefore, I should be free to do with it what I want, including taking on additional risk as I see fit. It should not be harder to invest in leveraged products than it is to walk into a casino and gamble money away on slot machines. That is backwards thinking. I do not quite understand FINRA's intent with these regulation proposal, but I 100% oppose them through and through.