Subject: N/A
From: Ed Ferrick
Affiliation:

Mar. 17, 2020

 

Comment on SEC Proposed Rule #S7-24-15: 

I've been successfully trading L&I ETFs since 2016. Both Direxion and Fidelity Investments provided 
me with detailed information that clearly defined the risks associated with these investments, especially 
when holding for longer periods of time. Fidelity required me to sign a Designated Investments Agreement (DIA) before I could even begin trading L&I ETFs. The DIA explicitly warned of the risks involved and that these products were designed for experienced and aggressive investors. This warning also appears in the Fidelity trade window every time I buy a L&I ETF. 
I do not use L&I ETFs as long term investments (years) or even short term investments (weeks/months). I use them for day trading purposes and only rarely hold them overnight. I believe there are adequate investor safeguards currently in place and am opposed to any new rules that would limit options for investors and traders. That also includes allowing brokerages to decide if an individual investor should be allowed to use these products. Individual investors have a responsibility to do their due diligence. Those of us who do our due diligence should not have our investment options limited to protect those who do not. Options, currencies, and precious metals are also risky investments. If L&I ETFs are to be restricted in some way by the SEC, will the aforementioned investments be next? If these new rules are enacted, I believe my use of L&I Funds for the last 4 years should automatically qualify me to continue using these investments. Thank you.