February 26, 2020
I oppose proposed Rule #S7-24-15. For all my searching Ive yet to find what problem it would solve or even attempt to solve. So far it looks like a solution in search of a problem.
Certainly, leveraged and inverse funds have their unique characteristics and risks, but then each investment type does as well. And when a person undertakes to invest in any instrument, either they investigate and learn the characteristics, risks, dependencies, possibilities, and history of it, or they quickly learn to do so. Imposing rules and limitations cannot substitute for proper and in-depth study that any investor should do before investing. In addition, Rule #S7-24-15 may be so burdensome as to cause brokerage firms to discontinue offering them at all.
Many other investment vehicles carry serious risks of losing money, whether futures markets, shorting of stocks, stock options, or even simple investment in stocks, as many fail financially each year and result in worthless stock certificates. Yet these continue viability and offer unburdened qualification for investment.
In my work I have limited or no access to market information and alerts, as I travel, have many meetings, and long consultations. Inverse funds have provided me a valuable hedge in such cases. On two occasions that I can think of I returned to find the stock market had taken a significant drop that would have been damaging to my portfolio because I was not available to respond early and stop losses. In these cases an investment in an inverse fund saved me. Elimination of access to inverse and leveraged funds by my brokerage would increase my risks in investing.