January 30, 2020
Item 1: General Identifying Information
a. Is the firm a Commission-registered investment adviser or a broker-dealer?: NO. Just a regular Individual Investor, benefiting from Top Leveraged-ETFs. +60% in 6-months. Understand the downside risks FULLY.
b. What is the size of the firm in terms of:
1.) The number of retail investors (as defined in the release)? 0
2.) For Investment Advisers, regulatory assets under management? 0
3.) For broker-dealers, regulatory net capital? 0
4.) Other (please specify)? Individual Investor - $60,000 Invested
c. Please include any additional general identifying information that you wish to provide, that could add context to your other feedback on the proposal.
5+ Years of US Market Experience (Fidelity Account), Benefiting from Leveraged-ETFs since 2018. Returns +60% in 6-months, from Leveraged-ETFs (Net-worth $40,000-to-$63,000 from Jun2019-Jan2020). These products are great for small investors, as we cannot invest MILLIONs-of-Dollars for ordinary returns.
d. Does the firm accept orders from or place orders for the accounts of retail investors to buy or sell shares of leveraged/inverse investment vehicles (as defined in the proposed sales practices rules)?
NO.
Item 2: Cost to Comply with the Proposed Due Diligence and Account Approval Requirements
a. What do you expect the cost to your firm would be in order to comply with these proposed requirements (in terms of combined internal and external costs)?
1.) For an investment adviser (check one box):
2.) For a broker-dealer (check one box):
b. Are there any less expensive alternatives to the proposed requirements you can suggest that would still preserve the proposed rules intended investor protection safeguards?
Maintain the Level of Due Diligence as required for "Options Selling" approval, as Leveraged ETFs are NOT More riskier than those, in-fact MUCH less risky, as the Max loss is limited to the amount invested. And nobody in their sane mind will bet their house on such products. But with HUGE multiples in the long runs, 20x-to-50x in 10 Years (real performance), they definitely hold a small position in the Long Term portfolio.
Such Exceptional performance is being generated with their smart design, and a lot of investor education is available online for the same.
Item 3: Other Feedback on Proposed Sales Practices Rules
Instructions: Please include any other additional suggestions or comments about the proposed sales practices rules that you would like to provide.
There is a lot of education available to Investors online, please encourage better education.
Additionally, we also believe that some big Fund Managers, or Lobbies, might be interested in putting these down, as otherwise they CAN NOT beat their long term performance (not even come close).
So, rather than helping clients to TIME their investments into these, they might resort to have these blocked, just because some NOT-SO-SMART-PRODUCTS bombed here there.
(Attached File #1: pbajaj4269.pdf)