March 10, 2020
It has come to my attention that the SEC is considering new rules on the sale of leveraged and inverse securities, which would require submission of personal financial information and a qualification process. Although it is true that this investment class carries magnified risk, it is my belief that these risks are plainly stated ahead of purchase and that most investors understand how to manage them responsibly. To make their purchase more burdensome for both investors and securities dealers, and to deny privilege of purchase of some is both unnecessary and unfair.
Although I use leveraged and inverse funds only occasionally, they provide a valuable tool in my portfolio. I think it is inappropriate for the SEC to govern who may be qualified to utilize these instruments, and I encourage the Commission to step back from the temptation to intrude on the right of investors and their counselors to invest as they see fit. Emphasize risk ahead of purchase more strongly, as a precaution, but let investors stand on their own feet, without a nanny to set unnecessary boundaries.