Mar. 18, 2020
Comment on SEC Proposed Rule #S7-24-15: Inverse and leveraged funds are complex in nature and are not for the novice investor. When I initially bought a few of these funds, I was not knowledgable enough to understand their volatile nature, so I applaud your concern. After many years of owning three inverse funds, I sold two of the funds with hefty loses, and incurred a reverse split of 10 to 1 a few years ago on the third fund, which has never recovered. However, upon reading the letter from ProShares, it appears that your proposal to require financial information from the public to buy shares is the wrong approach. Leveraged and inverse funds must be labeled as very short term, not buy and hold, instruments (and may be similar to options without a time limitation), where the risk of losing substantial money is high. But, instead of restricting the public from buying these funds, the responsibility must be placed on the fund's management to insure that they are performing their fiduciary duty to protect investors, with solid warnings, for the potential of almost complete financial loss should the market go against them or the possibility of reverse splits. A better approach may be to rework these funds into some type of hybrid options strategy, that is more transparent to the investor. Regards, Brian Murphy