March 12, 2020
Proposed rule #S7-24-15 is a calamity about to be imposed upon investors, and serves only the institutional investors who can trade using other instruments in the same manner that inverse and leveraged mutual funds and ETFs are intended. If you put this rule into effect investors will lose an important tool that can now be used with their investments.
I am a Registered Investment Adviser who manages the savings of many families. Inverse and leveraged funds are a risk reduction tool that I use to hedge away market risk for my clients. This tactic allows them to experience a lower trading frequency and maintain long term holdings with lower risk.
If some investors use these vehicles inappropriately and lose money, they should educate themselves or seek the advice of an investment professional, not seek to take the same investment opportunity away from people who use the these vehicles and prosper.
There are disclosures about the risk of these investments already. If people choose to not read them, that is their choice. There is nothing that regulations can do to keep deliberately ignorant people from running off on the next fools errand, so don't try.
To take these valuable tools away from investors who use them appropriately is just wrong, and I would hope for a more intelligent approach to this issue by regulators than a ban that hurts more people than it helps.
Please do not approve proposed rule #S7-24-15.