February 20, 2020
This proposed rule is unnecessary, overbearing, and burdensome for all impacted parties. It will drive up overhead costs for all funds that trade in derivatives. Even funds where derivatives are occasional or used to mitigate risk in a portfolio, will have to assess, document, and potentially have to engage in a lengthy exception application in order to continue to offer their targeted value to investors. These costs will be passed on to investors in the form of higher fees associated with any funds that are even potentially impacted.
In addition, I am especially concerned about the proposed clause approval and due diligence requirements for approving retail investors accounts to trade in shares of leveraged/inverse investment vehicles. As an individual investor, I occasionally trade leveraged or inverse instruments when I have determined they are in my best interest. I, as most investors, am quite capable of assessing risk and my own risk tolerance. Those who cant, should hire an investment manager or get out of the market. It shouldnt matter the extent of an investors assets or the size of their portfolio. Small investors should not be excluded from the same opportunities that are available to large institutions.