From: John LaFave
Re: SEC File ref S7-24-15 released on Dec11-15 & SEC rule 18f-4
SEC: To Whom it may concern,
My name is John LaFave. I'm a private, individual investor. I actively traded the following derivative, leveraged etfs; UVXY, TBT, UYG, FAS, TQQQ, and UPRO. I trade all six of these etfs to Hedge or Leverage my long positions typically in the SP500 index and long term bond index funds. All six of these etfs currently meet my trading standards for minimum assets, daily trading volume liquidity, and known historical performance confidence.
I'm writing to support "Grandfathering" these 2x & 3x leveraged etfs offered by ProShares & Direxion companies to be exempt from any new SEC rules on 2x and 3x levered etfs that would or potentially could create investor trading fear to an extent that would cause traders to flee, and Proshares or Direxion to then shut down these large, actively traded etfs noted above.
As an individual investor, the ability to both easily Hedge and Leverage my long stock & bond index investments by trading leveraged etfs has been of great value to me. These leveraged etfs, in their current structure, have allowed me to stay fully invested in my long positions by virtue of providing me with positive trading returns on upside, downside, or volatility swings.
Individual investors have historically not had access to leverage outside of the far more costly brokerage margin accounts. I've found the etfs noted above to be more cost effective for leverage than a brokers margin interest account. Nor have I found a more liquid, tradable hedging system offering portfolio insurance for me. In their absence, as an individual investor, I would sell down long positions, and use more cash on the sidelines as a hedge to manage risk.
At the same time, I recognize and fully support the need for SEC review of all derivative leveraged funds to ensure they're not a house of cards. In that regard, I welcome the SEC review for improved market confidence in derivative leveraged funds. It's only thru my, and other traders experience, trust, and confidence in these leveraged funds that they provide any value and support to our stock and bond markets as a whole.