March 10, 2020
My comments are in regard to File Number S7-24-15.
I have reviewed the Proposal and have a few key concerns as a retail investor that has used these sets of products for many years.
1. I understand the funds and their risks and potential rewards, that is exactly why I use them. I don't need someone else making choices about my competence to use products I want to use to best manage the risk in my portfolio's...which is primarily how I use them. I need more choice as an investor, not less choice or a more cumbersome way to get there.
2. Leveraged funds are a key part of my portfolio risk management. The ease of use and cost advantages make them easy for a prudent investor implement to help protect their investments. It would be a drain on me if that were some how taken away or those firms that offer these firms were given many more "compliance" hurdles to deal with. I appreciate these funds and the companies that stand behind them.
3. Inverse Funds are also an important way I protect my portfolio. Case in point is the market melt down happening right now. Volatility has shot up dramatically and the market has plunged while trying the deal with Covid-19 and more recently the Oil price war. Days like today where the circuit breakers on the market are triggered I am sure grateful to have inverse funds to rely on.
Please make it easy for individual and retail investors and those who help us. We have enough complexity to deal with as it is.