March 10, 2020
The benefits to investors of having their personal financial information screened by third parties as a condition to investing in inverse funds may include lower financial stress to ill-informed investors and to investors with bad judgment. The costs, in terms of burdens on the third parties and on all investors in such financial instruments, seem likely to outweigh these benefits (and certainly would in my case).
I would strongly urge the SEC to continue to rely on the role of accurate disclosure of risks in such investments, since such disclosure is the mainstay of US securities law. Asking third parties to make assessments of individual investors' financial condition (which is itself a not infallible proxy for good judgment) is intrusive and introduces a host of new liability issues that we really don't need as a country.