March 4, 2020
Gentlemen: I oppose the further rulemaking regarding derivative investment vehicles. As an individual investor who uses various derivatives to hedge my investments, I have already been thwarted by Vanguard, which now prohibits use of these tools. I suspect their prohibition is a direct result of your proposed rulemaking, and I have been forced to another broker to acquire the desired vehicles, adding to my expense and inconvenience. Each such vehicle I have examined includes extensive disclosure of the risks involved in using their investment vehicle, and it should be the investors' responsibility to evaluate that risk in their personal situation. If you make the process even more cumbersome than it already is, more brokers will simply prohibit these vehicles from their platforms just as Vanguard has done. The SEC has long provided valuable regulation, but we do not need another "Nanny" in Washington. Please get on with your important and necessary business, and stop interfering with legitimate investment tools.
Very truly yours, James F. Putman, Individual Investor,
CPA (ret.), CFP (ret.), Adjunct
Prof.-Accounting Finance (ret.)