February 17, 2020
Item 1: General Identifying Information
a. Is the firm a Commission-registered investment adviser or a broker-dealer?: NO
b. What is the size of the firm in terms of:
1.) The number of retail investors (as defined in the release)?
2.) For Investment Advisers, regulatory assets under management?
3.) For broker-dealers, regulatory net capital?
4.) Other (please specify)?
c. Please include any additional general identifying information that you wish to provide, that could add context to your other feedback on the proposal.
I am a retired private investor who uses Leveraged/Inverse ETF's frequently in managing my retirement funds. These instruments are very important to experienced investors with limited means.
d. Does the firm accept orders from or place orders for the accounts of retail investors to buy or sell shares of leveraged/inverse investment vehicles (as defined in the proposed sales practices rules)?
Item 2: Cost to Comply with the Proposed Due Diligence and Account Approval Requirements N/A
a. What do you expect the cost to your firm would be in order to comply with these proposed requirements (in terms of combined internal and external costs)?
1.) For an investment adviser (check one box): N/A
2.) For a broker-dealer (check one box): N/A
b. Are there any less expensive alternatives to the proposed requirements you can suggest that would still preserve the proposed rules intended investor protection safeguards?
Investor education is the best and lowest impact method. The Direxion Company is a good example of publicising their funds and providing all of the cautions needed.
Item 3: Other Feedback on Proposed Sales Practices Rules
Instructions: Please include any other additional suggestions or comments about the proposed sales practices rules that you would like to provide.
The public will see this as another method to discourage individual investing and to promote the need for commissioned Advisors (who are not required to have the interests of the client as a first consideration).