February 20, 2020
I'm writing to comment on the proposed rule to change or restrict the ability for me to trade inverse or leveraged exchange traded funds. I'm sure the intent is to protect those investors that might not be aware of the risks associated with such funds, but by there is clearly a warning for such investments already in place. Limiting the private or unsophisticated investors ability to include such funds in a personal portfolio would drastically limit my flexibility and give institutional investors yet one more advantage over the smaller investor. I have been investing in the market for about 15 years now, initially with a very small amounts of my savings. Though my small personal holdings are nothing compared to the millions of dollars invested by large firms, it's easy to argue that the personal investor has much more concern over the performance of their holdings. These are our personal investments in real world dollars and cents, and not the investments of an individual trying to perform well at the workplace in numbers and percentage points on paper and in reports. Over the last 15 years I've relied heavily on 3x leveraged ETFs and have seen gains that would never have been possible for someone with such limited cash available to invest. But of course I have also seen funds drastically decline in value, my personal value, making it impossible to ignore the volatility and extreme risk associated with them. Though I have no formal education in market trading, or even much more education than a high school education for that matter, the decay or beta slippage associated with such funds is a simple concept to understand. And not only does the simple unsophisticated investor like myself understand them, but we actually feel the impact of their tendencies in our personal nest eggs. So in many regards, investors like myself are actually more keenly aware of the risks associated with these types of funds. I have been trading and investing, with my own hard earned dollars in many different leveraged ETFs since their inception, making me as experienced and familiar with their unique characteristics as anyone. As long as the proposed rules do not limit someone like me from investing in them, then I have no objections. But if they favor institutional investors because a fund manager might have a formal education on the risks involved or a large amount of other people's money available to invest, then I argue the real world lessons learned far outweigh those taught in any classroom and the regulations proposed are actually backwards.