February 20, 2020
I regard the use of leveraged and inverse funds as vital to my investment success. They reduce my dependence on options and "going short". Both of which are far more dangerous than any ETF.
Having read the proposal (yes, all 445 pages) two things strike me :-
1) A complete lack of any evidence that consumers are experiencing problems with these products. The document is full of "examples" where the word "may" figures prominently. Leveraged/inverse ETF's are not new. They have existed for 10 years which is ample time to collect hard evidence. The absence of which leads me to conclude that there is no need for the proposed rules.
2) The proposal completely ignores the existence of ETN's. Considering the somewhat ephemeral basis of some of these, I wonder whether the SEC has sufficient understanding of market realities.