February 21, 2020
Dear SEC,
As an individual investor, I believe that the inverse leveraged funds play a very important role in allowing any investor of any size to hedge their portfolio against downturns. The funds should not be held for long periods, but any sized investor should not be deprived of the ability to protect gains utilizing these inverse funds. These investors should have a thorough understanding of how these funds work. Individual investors with odd lot positions in many stocks or funds are not in the position to write covered calls against possible drops in the market, where an inverse fund allows the ease for hedging. Leverage allows a smaller amount of assets to be utilized in the hedging process.
As far as the leveraged long funds go, I believe that there is less of a place for these, but still a place that would allow smaller, but sophisticated investors to participate in broad rising markets for limited time periods. In both types of instances, I do concur that the investor should be qualified in a manner similar to a margin account or options trading. Elimination of these funds would be a disadvantage to the small investors and likely create more market volatility. I hope that my comments are taken into consideration. I sincerely appreciate your interest in protecting the pubic. Please keep up the good work you do. Thank you for this.