February 20, 2020
I wish to express my great concern over Proposed Rule #S7-24-15 and I submit the following points:
1. What precisely is the worrisome problem that this proposal addresses? Leveraged and Inverse Funds have been on the market for many years now. Has the SEC been made aware of scores of investors adversely affected by these instruments that they need protection after all these years?
2. We are not living in the 1960s. With the advancement in technology and accessibility of markets through the rise of countless brokers and discount brokers, most investors are now quite knowledgable about the instruments they invest in. Those that invest in leveraged funds are quite well educated about the characteristics and risks/benefits of such funds, CFDs, futures, options, LEEPS, etc. There is ubiquitous education on these instruments freely available.
3. The SEC must preserve the freedom in public financial markets. Placing an onerous burden on brokerage firms will cause them to ABRUPTLY stop offering these products simply to avoid the red tape and administrative headache. A sudden such "stop offering" will cause myself and likely many others to be forced to liquidate my current positions at great loss.
I hope you will act in the interest of ALL parties.