February 19, 2020
I believe the proposed regulations are:
1. Bad for Investors. If the proposal is adopted, my clients, who benefit from the enhanced returns and portfolio, could be prevented from buying them by an overly burdensome qualification process. My broker might stop offering these funds due to the difficulty of implementing the regulations.
2. Unnecessary. The SEC has not shown there is a problem that needs to be solved with respect to leveraged funds. They have failed to show why these funds should be treated differently than thousands of other funds and securities.
3. A Dangerous Precedent. Requiring me to qualify to purchase a security in the public securities market would be an unjustified break with how the SEC's regulation of the sale of securities in the public market has worked for over 90 years. The proposal would be at odds with our long-standing system that gives investors and their advisors the freedom to make their own investment decisions.