March 10, 2020
6:19 AM 3/10/2020
Dear Security and Exchange Commission
These are my comments regarding a proposed regulation of restricting LI funds in retirement or taxable accounts.
1) I completely understand the characteristics and associated risks of the use of LI funds as an investment tool. I do not invest more than 2% in any single LI fund with a maximum of 10% of the total account value.
2) I understand the risks as stated in the prospectus for LI funds namely: a) They pursue daily leveraged objectives and, as such, are riskier. b) The principle of the bear fund achieving results are dissimilar to ETF's or mutual funds in that the value is the reverse, opposite or inverse to the index it is following. These funds are similar to shorting ETF's or a given equity. c) The performance of the fund (bear or bull) will be much more sensitive to the volatility of the market or its underlying index or sector.
3) Monitoring these types of LI funds on a daily or weekly basis is extremely vital to protecting is assets and I do monitor it daily and take steps when needed
4) The brokerage firm should not have the right to restrict the use of these investment vehicles based on their own established beliefs. Their role should be only to advise and receive the acknowledgment from the investor that they understand the risks associated with LI funds.
5) The prospectus provided by Direxion and other well established companies do provide a very comprehensive and language easily understood as to the principles and risks associated with these LI funds.
6) Should the SEC activate this new regulation then individual investors such as myself should be "grand-fathered" in to continue using these types of funds.
Please share this with Fidelity Investments
David and Janet Hart