February 25, 2020
Good Day: I appreciate the opportunity to comment on this potentially disastrous proposal. Indeed, I was appalled to learn of a proposal to restrict, or worse yet, eliminate the opportunity for individuals to purchase leveraged and inverse funds. This is a time of extreme volatility, with the further possibility of massive swings down for the stock market this year from multiple sources, including essentially uncontrollable algorithms. a possible pandemic and its impact on businesses, and to say nothing of the imminent election. I therefore regard it unconscionable to even consider the elimination of perhaps the only tool readily available to most individuals that can help avoid a personal financial catastrophe. The loss of the ability to use SDS and related vehicles eliminates my ability to rapidly respond to an unanticipated massive drop, from which at my age, I cannot recover.
This proposed action reminds me all too well of the result of the decision to eliminate the uptick rule shortly before the crash of 2008, and the later "flash crash." Had the uptick rule not been removed I seriously doubt the reactions in those two events would have been anywhere near as dramatic as they became in reality. Perhaps the size of the potential disaster in this instance might not be as large as those two issues, but it will have the same root cause - the deliberate elimination of a capability to limit losses imposed on individuals that could have easily been avoided. I cannot begin to imagine what positive good can result from this suggestion, except perhaps to those few specialists who make vast amounts of money quickly during periods of great financial unrest, without regard to the impact on individual investors, and the country as a whole. I hold the designations of ChFC and CRPC, and have served as a fee-only financial planner and RIA. I well understand the risks such holdings present for individuals. and am confident that it is possible to ensure individuals can be educated enough to utilize them properly if the sales forces are required to provide guidance necessary for buyers to use to their own advantage. Obviously it is not possible to protect all people from making errors in investing decisions, even with a proper amount of information provided at the time of their initial purchase of such a product. With that understanding, I ask that the "baby not be thrown out with the bathwater."
If the SEC is seeking a positive action they could take to stabilize investing, then please reinstate the uptick rule, and discard this concept of eliminating our ability to use leveraged and inverse funds for our own protection. Thank you again for providing this opportunity to comment, and for considering my concerns and suggestions.
nter your comments here.