March 16, 2020
Dear SEC Representative: Regarding Proposed Rule #S7-24-15:
LI Products have features that are not 100% unique and their risks associated with these products are different than the risks associated with other products but they are not 100% unique. I do understand the features and the risks of LI Funds.
I monitor the value of my account daily and check the value of the shares I own. I also understand how reverse splits work, how leveraging can increase the results significantly and how the Inverse component works in the opposite direction of the market. These are all risks that I am aware of and understand.
I believe that the clients and their brokerage firms should work together to determine if the client is competent enough to understand and assess the risks of LI and other public offerings.
Given the Prospectus provided by my brokerage firm and the disclosures and warnings it is extremely evident that there are significant risks with the leveraging, different multiples, and with the inverse relationship of the derivative to the product. My brokerage firm has provided me with sufficient warnings as well as information coming from the news media.
The derivative market is very large and there are many options to invest in leveraged or inverse products. LI Products just happen to provide both leveraging and the inverse relationship in the same product. These products are not for everyone.
I believe that I have participated in the trading of LI Funds in the past with sufficient knowledge of their workings and relationships. I believe that should automatically be qualified to continue to trade LI Funds under the new regulations. Thank you for your consideration, Michael Saliba