March 11, 2020
Thank you for allowing me to respond to the proposed rule change by the SEC.
I am a day trader and have been trading leveraged funds for a long time with success. They are my bread and butter. I only use them for trading short term positions. I also invest for the long term in non-leveraged funds,
I am a university-educated person and I fully understand the risks associated with leverage funds, e.g. the time decay and other inner workings. That is why I only use them for trading. I have been with my brokerage for years. They know me and I am allowed to trade options and futures at the highest level as well.
My brokerage should be allowed to asses whether I am capable of trading leveraged funds.
Since I am a day trade I monitor my account every day all year round. I make hundreds of trades a month.
Having said that once in a while unforeseen events take place, like the coronavirus, OPEC collapse etc. that may force your hand and hold your position underwater for a while. This happens but panic selling is the one thing NOT to do. It's mostly cyclical and coupled with the ability to trade the ETFs you can recover your position. Taking away this ability would be unconscionable.
Based on my experience and daily involvement in the market I should automatically qualify to trade leveraged funds.
I hope these comments are helpful in aiding you in your decision making.,