From: Gregory R. Bronner
I am strongly opposed to the imposition of this rule for the following reason.
Employees of funds that run index equity products are effectively prohibited from trading in most equities, as those equities are also traded by their firms. Imposing this regulation would eliminate the ability of thousands of highly educated and highly qualified investors to invest in levered long/short strategies that are not available through '40 act funds. It stands to reason that if an employee is qualified (by the SEC) to professionally invest others' funds, he or she ought to be able to invest his or her own funds.
Gregory R. Bronner