March 24, 2020
Item 1: General Identifying Information
a. Is the firm a Commission-registered investment adviser or a broker-dealer?: RIA
b. What is the size of the firm in terms of:
1.) The number of retail investors (as defined in the release)? 100
2.) For Investment Advisers, regulatory assets under management? 27,000,000
3.) For broker-dealers, regulatory net capital?
4.) Other (please specify)?
c. Please include any additional general identifying information that you wish to provide, that could add context to your other feedback on the proposal.
Firm name: Signal Research Group, LLC
d. Does the firm accept orders from or place orders for the accounts of retail investors to buy or sell shares of leveraged/inverse investment vehicles (as defined in the proposed sales practices rules)?
Item 2: Cost to Comply with the Proposed Due Diligence and Account Approval Requirements
a. What do you expect the cost to your firm would be in order to comply with these proposed requirements (in terms of combined internal and external costs)?
1.) For an investment adviser (check one box): $5,001 - $10,000
2.) For a broker-dealer (check one box):
b. Are there any less expensive alternatives to the proposed requirements you can suggest that would still preserve the proposed rules intended investor protection safeguards?
Item 3: Other Feedback on Proposed Sales Practices Rules
Instructions: Please include any other additional suggestions or comments about the proposed sales practices rules that you would like to provide.
The use of leverage and inverse funds is essential to our firm's management of client accounts. The use of these funds allows us to be more conservative and to protect clients during a market correction. The funds have been around for a very long time and I believe the public has a firm understanding of these investment products. Imposing additional rules and regulations would greatly limit our ability to provide our clients with the best investment advise we can. As a registered investment advisor, I have a fiduciary responsibility to put my clients' interest before anything else. Therefore, no matter what product or investment vehicle I'm considering, it will only be used if I think it is what is best for my client. Adding more rules will not change my responsibility, it will only make it more difficult for me to conduct business and carry out my fiduciary obligation. I strongly believe this proposed regulation should not be put in place.