February 22, 2020
subject: proposed regulations regarding leveraged inverse funds.
1)I protest the interference with any constitutional right regarding freedom of choice, specifically the freedom to execute my own investment decisions, to manage my risk and to manage my assets in the way I am most comfortable with pursuing. So long as those actions do not violate God's laws and are within legal boundaries of man law restrictions.
2) It is not the investment that meters risk, but the volatility. All investments require the management of risk and it is the investor's responsibility to learn to use the tools for controlling risk to achieve their level of comfort. Stop loss positions and position sizing do a very good job of managing risk. Not government regulations, they serve to color the water and complicate the process.
3) Establishing additional hurdles and limiting access to market opportunity through regulation is a very bad precedence. Regulations step into the "people control" domain and certainly insert some level of protectionism into a process that does not warrant government intervention beyond existing measures.
4) In establishing regulations governing access You are not acting to protect the uninitiated, you are acting on the investor not your typical IRA or 401K participant. Not the mutual fund holders, not the planed tax deferred programs, and certainly not the occasional buyer of a share in an ETF.
You are impacting a group of people that do not care to be saddled with someone else managing or telling them how to manage their money, their assets or their risk.
5) Regulations limit access, and in this case, to the very group of investors that might make use of such instruments to limit volatility. The use of inverse funds and leveraged funds provides for a lower volatility exposure in an otherwise very high volatility sector of the market. The depth of representation within a fund focused in this arena is far greater than the typical investor can accomplish, making them less volatile.
Additional constraints placed through volatility driven position sizing and the associated loss comfort of the investor further restricts available capital. Those restrictions significantly impact the number and size of positions that can be opened to achieve the desired objective.
6) So while these kinds of funds are volatile they are not as volatile as a single position holding. Regulating access serves to raise not lower the implicit volatility of the position.
As an investor I prefer to not have a government agency attempt to control my actions. I am opposed to the SEC implementing any additional restrictions of access to this or any other part of the market. We already have sufficient, if not overly ambitious, regulation hurdles to overcome. Especially so if we choose to do so in other markets, other time zones, or in other investments inclusive of bonds, warrants, shorts and options. In essence I am opposed to a government that is proposing limiting alternatives and access.