February 1, 2020
I write in strong opposition to your proposed rule S7-24-15 (Release No. 34-87607), insofar as it relates to proposed restrictions on the use of leveraged and inverse ETFs.
I am an individual investor, and I have used inverse and leveraged ETFs for many years.
The availability of such ETFs is very important to me. Such products allow me to take a short position, while avoiding the logistical problems of actually shorting, and also avoiding the undesirable characteristics of long put options.
The availability of these products enables me, as a small investor, to do what, in the past, could only be done by well-capitalized professionals.
Your stated purpose is to protect the small investor. But I submit that, rather than protecting such investors, you are proposing to make it much more difficult for small investors to compete with the same advantages now available to hedge funds and other market professionals.
In short, your proposal will do more harm than good, and will hurt the very people you intend to protect.
I am well aware of the risks associated with leveraged and inverse ETFs. But I am the one who is best qualified to evaluate my own portfolio. It is not appropriate for others, including the government, to make investment decisions for me.