January 30, 2020
I oppose these proposed regulations for the following reasons:
(1) I am thoroughly capable of understanding the characteristics and risks of leveraged and inverse funds. I have no desire for a third-party to evaluate my capability to apply these products to my portfolios. I certainly do not want a third-party to potentially limit or prevent my use of leveraged and inverse products.
(2) Leveraged and inverse funds provide the opportunity for me to seek enhanced returns and to mitigate risk in my portfolios.
(3) I seek to preserve access to buy and sell public securities in the public markets without the imposition of restrictive regulations that would complicate, and potentially eliminate, my freedom to do so.
(4) The addition of these restrictive regulations will create less liquidity in these products and, in turn, reduce their availability to only a wealthy elite.
In conclusion, there are adequate safeguards already in place through the registered brokerages and securities dealers who provide clients with descriptions of the characteristics and risks associated with leveraged and inverse funds. Consequently, these proposed regulations merely add unnecessary burdens and hardships to common citizens who seek to protect and enhance their portfolios with products available on the open markets.