March 12, 2020
I am completely against Leveraged and inverse ETFs having CFTC-like restrictions. I actually switched all my accounts after 25 years at Vanguard to Schwab for this reason. The Vanguard equity mutual funds I owned had 180-day trading frequency restrictions so I could not sell in October 2018 when my models turned RED. So I bought SDS against 50% of my position and saved a lot of money. Then Vanguard decides to bar its clients from using SDS. So I left. Now, you are tying Schwab's and other conscientious but non-restrictive brokers' hands against treating clients as adults.
What you are doing is denying investors access to risk-management tools - the opposite of what a regulator should be doing. I'd rather see you require all electronic brokers to print the pervasive yellow triangle with the exclamation point next to the fund when someone attempts to place an order - saying "Potentially Risky Instrument: Please read fact sheet before placing order." In this way, everyone is alerted that these are a little more complicated than most ETFs but can still make the adult choice of whether to buy and sell. This is the core of capitalism - allowing rational adults to assess risks for themselves and make their own decisions.