March 2, 2020
Dear SEC Official,
I am very opposed to the proposed regulations that would make it more difficult for a consumer to buy leveraged products or regulations that could prevent a consumer from buying them again.
I personally own leveraged funds.
I am very capable of understanding the risks and benefits associated with leveraged and inverse funds. I earned a Doctor of Jurisprudence Degree from Texas Tech University. I don't need a paternalistic third party evaluating my capability to participate in a leveraged fund. However, I believe that even persons with a high school level education can understand the nature of these leveraged products by looking at charts of their performance over years. Yes, leveraged funds are volatile but they can also produce dramatic increases in wealth. Driving an automobile can be very risky and even deadly and yet there is no proposal to ban citizens from driving because some drivers are irresponsible.
The use of leveraged funds is something which I have engaged in for years and it has not lead me into poverty or bankruptcy. I am counting on the leveraged funds to provide some strong financial performance to a very small proportion of my overall investments. I have less than 2 percent of my investment assets in leveraged funds. So, even if I lost half or more of the 2 percent, it would have very little impact on me. Obviously, I have the ability to sell leveraged funds on any weekday to avoid even a 20 percent decrease if I decide to do so.
I would prefer that the regulations pertaining to leveraged funds not be altered from their current status.
People are always going to be doing irresponsible things such as drink alcohol at extreme levels, etc. Yet, we can't remove every risk from society by banning alcohol or leveraged funds just because some people will abuse them.