February 14, 2020
Item 1: General Identifying Information
a. Is the firm a Commission-registered investment adviser or a broker-dealer?: No this comment is from a very active investor that utilizes TQQQ and SQQQ and other leveraged/inverse investment vehicles on a regular basis
b. What is the size of the firm in terms of:
1.) The number of retail investors (as defined in the release)? 1
2.) For Investment Advisers, regulatory assets under management?
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.
this comment is from a very active investor that utilizes TQQQ and SQQQ and other leveraged/inverse investment vehicles on a regular basis
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)?
this comment is from a very active investor that utilizes TQQQ and SQQQ and other leveraged/inverse investment vehicles on a regular basis
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):
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?
leave them the way they are today
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.
Leave them the way they are today. I utilize these vehicles extensively and would like to continue. Leveraged and inverse funds are important to me, and they allow me to seek enhanced returns and help protect my portfolio.
I am capable of understanding leveraged and inverse funds and their performance characteristics, and do not want a third party evaluating my capability to do so and potentially preventing me from buying them.
I want to preserve the long-standing free public markets where investors and their advisers have the freedom to buy public securities without government-imposed limitations on investor choice.