February 19, 2020
Dear Sir or Madam at the SEC,
Leveraged and inverse funds are the ONLY way by which an individual investor can even attempt to compete with large financial institutions, hedge funds, quants, and other funds that have incredible advantages over an individual investor like myself. I dont have the research they have, nor the resources, nor the contacts, nor the math prodigies to create the returns they enjoy.
Leveraged and invest funds are my only potential opportunity to create a meaningful return in the marketplace or to have a meaningful hedge against losses.
I am more than capable of understanding a simple principle where the returns, for better or worse, are multiplied by a factor of 2 or 3. I learned all about multiplying a number by 2 or 3 in third grade. These products are not difficult to understand.
The very last thing I need is the government to take away my only form of leverage. Why would my own government do this to me? I am a good citizen and I abide by all laws. Why deny me my one vehicle to realize meaningful returns?
Our country is strong because, in part, our commercial marketplace is strong and free. Please let me continue to use investment tools which have allowed me to fund my daughters education and to create retirement savings. Moreover, when I eventually liquidate the tax deferred accounts the government will be a winner, as the taxes I pay will be on my outsized returns, which would have come from these leveraged products.
Finally Id like to note that any investor who claims to not understand that he or she is buying an ETF with a leveraged or inverse return of 2 or 3 times the assets value (whether as losses or gains) is simply not being honest. The funds themselves provide ample and redundant notice of the leverage also the leverage is even in the title of the funds. Most likely those individuals who complain about their returns simply (i) didnt take the time to determine which funds they should buy or sell and when they should do so or (ii) are too lazy to take the time to educate themselves on when to use these SIMPLE instruments.
Neither this government nor any other government can issue decrees or regulations outlawing laziness, greed or foolishness. If these funds are outlawed or greatly burdened by some subjective matrix which would determine investor sophistication , however that impossibility might take place the government will find that those who had poor experiences with the subject funds will simply seek out get-rich-quick schemes on the internet of which there are many: colonial Spanish coins from shipwrecks, rare stones and gems, life policies which are too good to be true.
Please let alone a product group and a system that works. Let me use it to pay for my daughters education, for my wifes retirement and mine and to give the US government the tax revenue flowing from those gains.
Let the little guy the sole investor without a support staff or fancy software and proprietary logarithmic calculations, continue to use these simple products.
Ive lost money on occasions with these funds but when I do its because the market simply contains inherent risks. Everyone knows that. Who has not heard of the Great Depression or the more recent Great Recession?
Please leave well enough alone. Please dont eliminate nor complicate a product group that Ive used with success for many years. Its just not fair.