March 14, 2020
Dear SEC Chairman Jay Clayton,
I understand that you, the SEC, is considering a proposal to make it burdensome for investors like myself from trading, or even PREVENT me from owning, leveraged and inverse funds like ProShares. I am completely AGAINST such a proposal
Look, I am a small investor. I retired as a civil servant civilian after working for the U. S. Air Force for 32+ years (6+ years were on active duty). My wife is a retired high school teacher. While we only have reasonable incomes, we both do have Roth and Traditional IRAs as well as modest real estate investments. Under my Traditional IRA, I do trading in stocks, as well as ETFs and ProShares. I do this trading inside of this Traditional IRA so that I do not have to be burdened with reporting each and every buy/sell investment on my Federal Income Tax filing each year. Because it is within that IRA, I only have to report what I actually take as a distributed - this is a simple and unburdensome process which makes life easier for me. In the last few weeks as the norovirus scare has taken place and the market have gone down by 25+%, there have been several big down days when my full Traditional IRA account went up because about 1/3 of the funds in it are invested in a inverse fund (DXDs). This capability to stabilize my entire portfolio has been invaluable to me Your proposed burdensome rule would either make this extremely cumbersome for me to do this type of investment, or even eliminate it altogether Either situation is unacceptable
Another thing to consider: Should you institute such a harsh rule, what is the SEC going to do about people and accounts that already own them? Will they be able to keep them? Or will they have to be changed over to other investment instruments instantly? In 3 months? In 6 moths? In a year? When markets can change so quickly, just look at March 2020 alone as an example, those of us that already have ProShare type investments may be drastically hurt as everyone tries to unload their shares at the same time Look what happened in oil recently THIS will be REALLY GOOD for the small investor NOT
I see no reason why a small investor like myself cannot be allowed to invest in these instruments. Your proposed RULE for over burdening me with a cumbersome qualification process in REDICULOUS I understand that some brokerages might actually even drop investment types like ProShares because they do not wish to be overwhelmed with YOUR (SEC's) proposed process. Look, I believe in free and fair markets, and I see no reason NOW for the SEC to overstep the public markets. Because you have provided no proof that this rule is actually needed, I believe that the SEC's Proposed Rule #S7-24-15 is overstepping your authority, is unnecessary and is stupid
PLEASE DO NOT IMPLEMENT THE PROPOSED SEC RULE #S7-24-15
Richard Hunziker
Florida