January 30, 2020
When purchasing any security, the onus should be on the investor (or advisor with discretion) to understand what they are doing. These funds are important to my firm, we have the expertise and experience to use them wisely. If others do not, they should not buy them. We have discretion over our clients money and if we mess up it is on us... therefore WE are the ones responsible for the due diligence. Forcing us to get approval and undergo the requirements in the proposal would be unnecessary red tape.
Perhaps new rules can be made to limit predatory sales of leveraged funds... but similar logic should apply to ALL funds. Also, firms like mine, an SEC regulated RIA, should be excluded from any rule like this.
Many (most?) people are not capable of evaluating the SIMPLEST of investments out there. This proposal is trying to solve a problem that shouldn't be fixed.
We do not need approval from a regulatory body to do our job.