March 10, 2020
I have been investing for more than 20 years, and I use leveraged instruments to amplify returns during bull markets and inverse leveraged instruments to hedge against the risks of doing so. My investment strategy has allowed me to maximize my returns over the years, and the existing disclosures in the prospectuses of these investment vehicles are adequate for me to make informed decisions about the relevant risks. I do not think my brokerage firm or the SEC should be able to unilaterally determine whether investors are allowed to use such products. The ability to quickly enter and exit these transactions through ETFs -- as opposed to designing and utilizing more complicated means to do so with derivatives and margin trades – allows sophisticated investors to appropriately assess their risk tolerance and act accordingly. This regulation would do nothing other than foreclose a useful device that certain investors utilize to take advantage of market conditions. It should be rejected. Thank you.
Derek Kaufman