February 18, 2020
I'm writing to comment on S7-24-15.
As the old saying goes, "if it ain't broke, don't fix it". I don't see where leveraged funds/ETFs are any different than any other investment vehicle that is available to the public and therefore, no special regulation limiting access to them is needed. Almost any investment has risks associated with it and it is up to the investor to due his or her due diligence on whether those risks are worth the potential return. Understanding leveraged ETFs and their performance characteristics should be left up to the individual investors and the free market, not a third party in charge of evaluating the capability of investors to buy them.
I personally run a business that is based on using leveraged ETFs and this regulation would ruin that business. Leverage ETFs are important to my business and they allow me to seek enhanced returns. It is even stated in the report that the SEC is uncertain as to the effects this regulation will have "Where possible, we have attempted to quantify the likely economic effects however, we are unable to quantify certain economic effects because we lack the information necessary to provide reasonable estimates. In some cases, it is difficult to predict how market participants would act under the conditions of the proposed rules."
So, as I can see it, there is no problem that needs to be addressed but the SEC feels there is a need to make a regulation that they even admit they don't know what the effects will be. It is bad for investors, unnecessary and would set a dangerous precedent.
Please consider my comments in your decision. Thanks.