February 15, 2020
As a retail investor I object to the imposition of this rule as it affects the average retail investor with respect to inverse and leveraged ETFs. Sealing off retail investors from these instruments will prevent the average person from protecting himself in the event of an economic/market meltdown. The paternalistic intent of the proposed rule is evident from the fact that such instruments are not banned for all investors. The big players will still be able to use such instruments to protect themselves from risk, and the economic impact of this behavior by big investors far outweighs any potential impact from allowing small investors to use them. The proverbial little guy will be barred from using tactics and instruments that the big investors use to their advantage. This will further discourage the small investor from participating in the market. Moreover, it embodies a false narrative (applicable only to the small investor) that the market can only go up. In a market meltdown such as occurred in 2008 there will no place to hide for the small investor. Thus he or she would be well advised to stay out of the market altogether and hold only cash. This is not a good outcome for either the individual investor or the market/economy as a whole.