March 12, 2020
Good Morning,
I wish to express my interest in continuing to buy and sell LI Funds. In general, I believe all investors have the right to buy and sell any funds available to them by their brokerage firm or financial advisor. I treat these funds very seriously and track them at least multiple times a day during every trading day and due my due diligence regarding research and thought process before I decide to invest in any of them.
In regard to my buying and selling LI funds, I am well aware of the elevated risk associated with them including the need to frequently throughout the trading day watch these investments, that holding them for any period of time, particularly during times of high volatility in the sector, can cause "decay" with the daily rebalancing and compounding can lead to complete loss of my initial investment, even within one day.
Regarding the risks in general of LI funds, I understand and accept the effects of compounding and market volatility risk briefly described above, derivative's risk, counterparty risk, market risk, energy sector risk, and specifically with oil and gas industry risk with funds such as GUSH/DRIP/UWTI etc, especially in this current market and overall global sentiment on fossil fuels, intraday and tracking risk, high-portfolio turnover risk and general risks such as cybersecurity risks/trading halt risk and investment risk.
The idea that a brokerage firm, or the SEC for that matter, has the right to decide if I or anyone else has the knowledge and intelligence to sufficiently gauge the risks especially when they are included in the Prospectus of a Fund, and potentially disqualify them from buying or selling a publicly offered investment is wrong and more than unsettling. Brokerage firms clearly spell out the risks of every fund, including the LI funds, in their Prospectus.
As someone who has been trading in LI funds for quite some time now and monitors their accounts at least multiple times a day during all trading days, have developed more experience with their use and believe this should automatically qualify me to continue to trade in LI funds under the proposed regulations.
Thank you for your consideration,
Kenneth Ferrato