February 2, 2020
To Whom This May Concern,
I am an individual that has been investing in the market since I was 16 years old. Over that time I have exclusively invested for myself and have been fairly successful. I started trading individual stocks and have moved almost exclusively to index and sector ETFs. In the past, I have used both leveraged and inverse ETFs in my trading and they have been indispensable. I am well read and researched and am certainly capable of making my own investment decisions.
So, when I heard about the SEC's proposed rule S7-24-15, I was disturbed to say the least. The SEC plays a vital role in promoting fairness and protecting investors, but this proposed regulation goes too far and I believe it will actually hurt investors more then protect them. Here is why I am firmly against the proposed rules:
1.) It could prevent investors like me from being able to purchase these leveraged and inverse ETFs if the fund companies determine that the regulations are more hassle then they are worth.
2.) Unlike other trading methods using margin or options, which have unlimited downside risk, these ETF products limit losses just to the amount invested - just like any other stock, ETF, or mutual fund.
3.) It's not clear why these ETFs are any different, and should therefore be treated any differently then any other securities that are available to invest in.
4.) As mentioned, I have decades of experience investing, and I don't need a third party to evaluate my capability to make trades and decide whether I should be able to make these investments.
5.) I currently have a position that could be drastically affected by these rules. Should these rules go into affect, it might force me to vacate that position before I'm ready to, which would cause me to lose a significant amount of money. Only I should make the choice when to sell this position.
Thank you for your consideration,
Jason