April 17, 2020
Strongly believe the proposed regulations are not in the interest of Investors. Some investors who could benefit from the enhanced return and portfolio protection potential of leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process. Brokerage firms could even stop offering these funds altogether due to the difficulty of implementing the regulations.
In addition, there is no evidence there is a problem that needs to be solved with respect to leveraged and inverse funds. These funds are no different than tens of thousands of other public securities, each with their own characteristics and risks.
The proposal would be at odds with tradition of giving investors and their advisors the freedom to make their own investment decisions.