March 3, 2020
Im a qualified investor so this change would not significantly affect me. However, I do not think it is necessary since the current margin regulations cover the volatility of any leveraged securities.
While the existing rules for qualified investors for private placements make sense because the volume is low and the risks are unknown, the volumes for securities including Proshares make it impractical and the relationship to the underlying security is clearly defined.
Adding a recording requirement could add costs to brokers for no obvious benefit to investors.
Finally, if such a requirement had been in place when I started trading this type of security it might have prevented me from taking advantage of the opportunities available to wealthier investors.