April 8, 2020
Leveraged and inverse funds allow our firm to hedge client's portfolios in an efficient manner. Access to these types of funds are very important to our firm and our clients who look to us to not only help them achieve their goals for growth, but to also protect the growth they have achieved against loss. This rule should not be implemented, as clients, especially those who do not have the capital and account sizes for other options, would be disenfranchised. Clients have contracted with us to use our experience and expertise to make these decisions for them and this rule would override that contractual relationship and our ability to do what we think is in the best interest of the client and our fiduciary position.