February 7, 2020
I am an informed investor who has considered leveraged ETFs' return-variance optimization in a diversified portfolio, ETF fees, and ETF rebalancing costs. Every person I know that uses leveraged ETFs understand the risk. This new rule is unnecessary. By making it burdensome to invest in and operate leveraged ETFs, this rule risks eliminating such ETFs from the market or increasing their costs. This is unfair to small investors like me who lack the scale to borrow at a low rate and thereby achieve leverage.