February 28, 2020
To the SEC Re: SEC File ref S7-24-15
Please do NOT adopt the proposed rule.
Under these proposed regulations, I would be required to provide extensive personal financial and other information and be evaluated to determine if I will be allowed to buy leveraged and inverse funds. This is an unnecessary and intrusive burden on me as a client and on my financial advisor. It sets a troubling precedent for the SEC to insert itself into investment decisions at the personal level.
All investments carry risk. For instance, it is conventional wisdom that bonds and bond funds are a safe investment. However, they are vulnerable to interest rate risk when rising rates lead to falling prices. Interest rates are at historic lows, approaching zero, and so have nowhere to go but up. And yet regulators are not stepping in to determine if investors qualify for the risk that bonds pose. It is inconsistent for them to do so for leveraged vehicles.
If implemented, this proposal will change the rules in the middle of the game and would damage my portfolio which has a long standing leveraged and inverse strategy. Also, such a burdensome qualification process could force brokerage firms to stop offering these funds altogether and thereby rob me of the future gains anticipated by this strategy.
Leveraged and inverse funds are an important part of my portfolio. They allow me to seek enhanced returns and help protect my portfolio against the risk of an aging bull market downturn.
I understand leveraged and inverse funds and their performance characteristics, and I do not want a third party evaluating my ability to do so and potentially preventing me from trading them.
I want to preserve the institution of free public markets where investors and their advisors have the freedom to buy public securities without additional government-imposed limitations on investor choice.