January 20, 2016
Dear SEC,
I am a young investor who has studied the market, and I believe that leveraged ETFs are one of the best ways that I can make money over my career as a dollar-cost averaged long term buy and hold. I hope that this opportunity isn't taken away from me because of the need to protect other investors from misunderstandings on the risks associated with how these products work.
I fully realize the risks of using leveraged ETFs and how they work. They reset on a daily basis, meaning that they do not correspond to a 2x or 3x gain or loss over the course of more than one day. Volatility in the market eats away at profits. Over periods where the market is flat, these funds lose value. And similarly, even if the market goes up, these funds may not. There is also risk that the counterparties in swap agreements may not be able to hold up their part of the bargain.
I have run many simulations over market data from 1950 to 2015 using hypothetical 2x and 3x leveraged ETFs (corresponding to ticker symbols SSO and UPRO), and I believe that they are one of my best choices as a long term buy and hold. I plan on investing every year for 30 to 40 years. This would have been a much better plan than to buy and hold the SP 500 over almost any such historical period. I can back this up with data, which is attached in the comments.
At the same time, I understand that past performance does not indicate future results. If the markets are more volatile in the future or do not yield sufficient returns, then I could lose money on my investments over the long run. I could lose all of my money invested in the UPRO if the market dropped by 33 percent in a single day. However, these are risks that I am willing to take.
Please reconsider this proposal. It will hurt retail investors who understand these products and the risks involved.