February 19, 2020
My comment regarding suggested rules for trading inverse and leveraged ETF and ETN.
I am a retail investor with 20+ years of self-guided investing and stock trading experience. In my opinion investing in leveraged and inverse ETF and ETN has much more favorable risk profile than trading options. Historical prices for leveraged and inverse ETF and ETN are freely available to retail investors (Yahoo Finance, for example). Therefore investors can quantitatively analyze possible risks associated with use of these products. No such information is available for a huge universe of options. Therefore investing in leveraged and inverse ETF and ETN is much safer than trading options. Accounting for associated risks shall be responsibility of market participants since they have necessary information at their disposal. Imposing option-like rules would be excessive and burdensome, and not warranted by nature of these, leveraged and inverse ETF and ETN, securities.