February 19, 2020
To whom it may concern: Currently as an individual investor with almost 52 years of experience in the market, most of it as a series seven and series 26 representative and manager. I am surprised that the SEC is considering delegating an investor's choice of investments for an individual to someone other than the individual.
I personally enjoy the choice of sector and select ETF's as a preferred pick. Individually I do not have the resources or time to research the particular performance of the SP, Nasdaq, and Dow 30 as three examples, representing (mirroring) approximately 630 different stock picks and to have different firms offering them for the individual investors to choose the firm or firms they wish to invest in and monitor their competitors performance, is superior (in my opinion) to any method I have seen proposed by current brokerage or investment firms for the average investor, who cannot qualify at the high dollar amounts required for firms like Goldman Sachs and etc. The idea that in a down market an individual investor (by Government decree) cannot choose to offset the losses being realized by investing in the continuation of that down market (Inverse ETF's) speaks very poorly about our rights as individuals to decide our own path and presumes that risk and reward is not the name of the game, at least not in the eyes of our regulators.
I would suggest that the ETF firms have disclosures about the risk of leveraged or Inverse ETF's (not the passive sectors ETF's) according to their market gain and or loss in a percentage number. In example 1 is passive, two is 100% greater risk than 1 is and so forth.
Most firms and managers try to beat the SP 500 and earn a fortune doing that. The majority fail all of the time, yet the SP 500 ETF SPY mimicks it Without the huge expense of a managing firm. Mutual funds were the choice of the average firm (and today because of sweetheart deals with those fund companies many firms do not allow the individual investor to participate in the choice of an ETF investment within their firm) and I am crass enough to believe that is because ETF's do not charge the investor all of those inside fees that promote what I call the misuse of earnings that should have been realized in their whole by the investor. Rather a flat basis point or percentage on the purchase or sale of the investment (or an ongoing fee based on the amount invested with that firm) that can be fairly compared to other firms including those that have up front commission charges.
I appreciate the alert from your firm. The right of the Individual to decide their investment path should not be abridged if possible, but allow the market to create even more creative means of investing (currently ETF's) under the real test of competition. If further disclosure is required (as mentioned above), make it. Regulating my level of risk and reward or confidence in a particular ETF provider should not be a bureaucrat's decision in our country.
Sincerely: Richard Nord