February 19, 2020
I understand that the Securities and Exchange Commission has proposed new regulations (The Investment Company Act) that could impact investors in leveraged and inverse funds.
There is a benefit in providing risk management guidelines to fund managers. However, having a firm / broker) determine whether to approve a retail customer or clients account to buy or sell leveraged investment vehicles, and approving the account if it had a reasonable basis to believe that the customer or client is capable of evaluating the risks associated with these products, is intruding on the rights of the investor.
Leveraged funds provide a convenient manner to improve returns, similar to both call and put options. Again, it is up to the investor to understand the published risks, not government oversight. Markets work best when they have minimal control. Restricting the use of levered funds will force investors toward options and margin accounts, which are far harder to understand and use.
Additionally, inverse funds afford small investors an easy way to invest in and provide account protection in falling markets, and install support for a falling market when those funds are redeemed, just like short positions. They are an important part of my portfolio, and I do not want a third party restricting or deciding who will be able to access either inverse or levered vehicles. An explanation of the risks to the investor, that is provided now, is more than sufficient.