January 29, 2020
I realize that both the SEC and FINRA have a longstanding practice of attempting to protect investors from their own stupidity.
However, this proposal is a terrible idea and represents a substantial overreach. Leveraged ETFs are a convenient way to match market returns while risking less capital. They are a valuable tool for investors who are nervous about or unfamiliar with the use of options.
A simple solution to protect novice investors from buying products they don't understand is to require that an account have options privileges in order to trade leveraged ETFs.
Please don't make it overly difficult to use these tools.