March 12, 2020
Inverse funds and leveraged ones serve as an insurance balance to other position holdings for one's portfolio. It's easy for retail investors to ride a wave of "hot" equity gains in a rising environment but aside from cash, options and margin borrowing, there are few ways to protect against DOWNSIDE risk and to seek basic (limited loss) leverage for a weighted allocation. Also, having these funds can greatly reduce the risk of margin borrowing that proves to be far more expensive and detrimental to individual investors. These products are well-made for individuals with basic needs. I've been an investor, had a Series 7 and worked in financial services. I understand and manage within regulations but am frustrated about the proposal's short-sightedness -- high restrictions. There are plenty of disclosures that speak to the risks of the products which is quite sufficient and comprehensive. Congratulations for mandating those but further restrictions are not necessary. Good luck in your work.