March 17, 2016
SEC: To Whom it may concern,
My name is Richard Mosley. I'm a private, individual investor. I actively trade derivative, leveraged ETFs.
These ETFs currently meet my trading standards for minimum assets, daily trading volume liquidity, and known historical performance confidence.
I'm writing to support "Grandfathering" these 2x 3x leveraged ETFs to be exempt from any new SEC rules on 2x and 3x levered ETFs
As an individual investor, the ability to both easily Hedge and Leverage my long stock bond index investments by trading leveraged ETFs has been of great value to me. These leveraged ETFs, in their current structure, have allowed me to stay fully invested in my long positions by virtue of providing me with positive trading returns on upside, downside, or volatility swings.
Individual investors have historically not had access to leverage outside of the far more costly brokerage margin accounts. I've found that ETFs are cost effective for leverage than a brokers margin interest account. Nor have I found a more liquid, tradable hedging system offering portfolio insurance for me. In their absence, as an individual investor, I would sell down long positions, and use more cash on the sidelines as a hedge to manage risk.
At the same time, I recognize and fully support the need for SEC review of all derivative leveraged funds to ensure they do not pose undue risk. In that regard, I welcome the SEC review for improved market confidence in derivative leveraged funds. It's only thru my, and other traders experience, trust, and confidence in these leveraged funds that they provide any value and support to our stock and bond markets as a whole.