February 21, 2020
I have for years been using leveraged and inverse funds as a part of my investment strategy and wish to continue to do so without additional effort to qualify by whatever standard. I understand the funds, know what I'm doing, and as I've learned from years of experience, I have recently relied increasingly on these funds to simplify and increase my returns. I see the cautious use of inverse funds as an important part of my bear market strategy when that time arrives. To be honest I resent the government's inserting itself through unnecessary rules and restrictions on brokerage houses to complicate and potentially limit or take away my use of these types of funds, and I strongly object to any efforts to restrict the long standing public securities market where I and other investors and/or advisors are in any way restricted in our personal financial decisions, which are ours to make, not the government's. I also recognize that some brokerage houses, having recently reduced investor costs through zero commissions, may choose not to deal with the increased cost of implementing your restrictions and thus eliminate the use of these funds all together, making them no longer available to many of us who understand the risk and use these funds quite successfully. Other brokerage houses may need to add or increase their fees to cover the increased costs that these potential restrictions would bring. In either case these restrictions would NOT serve the investors, as I would hope is your intent. The reality is we do not need or desire your "protection". We take full responsibility for our decisions and do not need the government making them for us or restricting our choices. I ask that this proposal NOT be approved.