January 30, 2020
As I read the proposed Rule I, as an individual investor, and as a taxpayer do not recognize any value or good reason for such intervention by the SEC. Those Funds, as well as most others, offer investors useful tools with which to manage our investments. Inverse funds are a useful tool for risk management in periods of probable declines and there is no reason for SEC to intervene and impose itself as evaluator and approver of which investors, if any, the SEC will allow to use them. Make the case for who is complaining and why, and the case that justifies why the SEC should intervene in such draconian manner. From this investor's perspective SEC is way out of line with this proposed regulation.
Screw up our investment market and you will drive capital, and investors who own it and work it, out of the USA, and onto non-USA markets.
Do your job as you are established to perform and keep out of unwarranted, rampant intervention into the markets when there is no justification. And when there is justification make the case for it and make the case for why SEC is the best choice for a solution, and then propose it with clear justification. Do your job.