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Dear Madam, Sir:
I am writing concerning possible restrictions that may be applied to certain securities like leveraged or inverse funds.
I am a private, non-professional investor, but do my homework on stocks. Especially in the last few years, leveraged and inverse ETFs have been an important part of my investment strategy. While they represent a lower percentage of my investment funds, they
I'm contacting you to oppose the potential additional regulation applied to certain "complex" investments.
First, what I choose to invest in, public or private securities or other instruments, is my sovereign choice. I educated myself on e.g. leveraged and inverse funds, and have an understanding in how they work and their risk/benefit equation as it applies to me.
It is me as a US Citizen and individual investor - not regulators who should be able to choose the public
investments that are right for you and your family.
Public investments should be available to all of the public,
not just the privileged.
We investors shouldn't have to go through any special process like passing a test before you can invest in public securities, like leveraged and
Elisabeth Craig is Senior Vice President & Deputy, FINRA, Credentialing, Registration, Education and Disclosure (CRED), responsible for oversight of registration functions and testing and continuing education.
Prior to joining FINRA, Elisabeth was employed as Counsel with DCS Advisory, an investment banking firm, where she focused on all aspects of legal and compliance matters. Elisabeth
In regards to your proposed legislation to apply special criteria to investors who wish to trade in some leveraged or inverse funds. At the best, the proposed legislation is an additional burden to investors. At the worst is that it is discriminatory that shuts out small investors in favor of wealthy investors an private wealth or hedge funds. I currently have held one of these funds for over 11
Dear FINRA, I oppose this legislation because you are instituting more constraints on my freedom to manage my investments as I see fit. We already must review and sign documents from our broker informing us of the risks and potential losses on all leveraged investments before we can purchase those investments. In fact, I had to state my investment objectives were "most aggressive" to
Any data that is communicated publicly should be communicated in the most efficient manner possible. In a industry where data is considered to be so valuable that firms were willing to spend millions of dollars to have their fiber optic cable runs as close as physically possible to the exchanges so they could get a timing advantage, the short interest report being collected only a twice a month
Rulemaking topics discussed include:
corporate financing,
margin requirements for security-based equity swaps,
membership rules, and
private placement filings.
Alternative, "alt" or “liquid alt” funds are publicly offered, SEC-registered funds that use investments or strategies that can differ from what is offered in a typical fund. Compared to more traditional mutual funds and exchange-traded funds (ETFs), liquid alt funds tend to hold investments that extend beyond equities and bonds or employ more complex or sophisticated strategies.
Frequently asked questions regarding FINRA Rule 2210, filing requirements and the how to use the Advertising Regulation Electronic Filing (AREF) system.