March 28, 2016
I do NOT support the proposed rule.
I am an independent retail investor. I have been trading leveraged ETFs (specifically triple/3x leveraged ETFs) on a daily basis since 2010. I am not "wealthy", especially by Wall Street standards. But these funds have provided me with an avenue to explore creative trading strategies and derive an income.
For those who might argue this type of trading is not productive to our economy, I would point to the significant fees and commissions that I have paid to my broker and ETF sponsors along the way. These firms have employees. A rule that forces the closure of ETFs will undoubtedly lead to job losses as a result of lost fees and commissions.
I understand that leveraged ETFs present pitfalls for inexperienced investors. I also recognize the need for reasonable oversight and regulation. But experienced retail investors who rely on these funds should not be unreasonably punished for the mistakes of others.
A rule that would result in the outright closure of 3x leveraged ETFs certainly seems unreasonable. Surely there must be some way short of a blunt instrument approach to protect retail investors. Enhanced disclosure requirements, such as requiring retail investors to sign an additional acknowledgement form (and providing it to their broker in original signature, not checking a box in a web browser)could achieve this goal.
Again I am just an average, experienced retail investor, not an industry insider. Nevertheless, it is not an understatement to say that the closure of 3x leveraged ETFs would threaten my livelihood. I have relied on their availability for the last 6+ years and have made permanent decisions about employment and lifestyle based, in part, on their continued availability.
Please reconsider the proposed rule. Thank you.