Mar. 17, 2020
Comment on SEC Proposed Rule #S7-24-15: It has been brought to my attention that your commission is considering adopting new rules regarding investment in leveraged and inverse funds, which would include a very burdensome qualification process - so difficult that some Brokerage firms might even stop offering these funds altogether. There have apparently not been any problems shown that would warrant such action, and the commission has not shown why these funds should be treated any differently that thousands of other public securities, all of which have various risks. You are changing rules that have worked for nearly 90 years. My husband had a PH.D in economics, taught at the university level for some years and was a registered investment advisor, heading his own management firm. I have a masters' degree in urban and regional planning, and while stock investment is not my milieu, I have some familiarity with the field, including possession of a chart of the stock market showing its fluctuations since the 1700s. You surely know that his market is over blown by a record amount, and at some time, not in the far future, there will be a major correction. My husband died last year (at age 86), leaving me with a portfolio that is invested in leveraged inverse funds. It is, of course, at a loss. I wish to be assured that I can retain my position in the two accounts until I choose to sell them. Philosophically, I want to preserve the long-standing free public markets where investors and their advisors have the freedom to buy public securities without additional government-imposed limitations on investor choice. Whatever is happening to our vaunted capitalistic system that sets the stage for individuals to make their own decision and accept the risk that entails? Regards, Dawn Chapman