March 16, 2020
From David L. Harris, PhD ChFC CFP
Re: Proposed Rule #S7-24-15
Dear SEC:
As founder and Chief Compliance Officer of HARRIS ASSOCIATES, A Registered Investment Advisor, I strongly object to efforts curtailing the use of leveraged and inverse ETF's and similar instruments.
These products are key elements of our investment management process. They are supplemental to core and sector holdings in portfolios and allow diversification and protection of client gains.
For example, from January 1st this year most of our clients were beating the indexes in account growth. When markets turned in mid-February we were able to trim assets, establish large money market positions and purchase inverse assets to hedge the accounts. The result is clients don't have to "Sell All" to mark time during this volatile time. This way clients will only realize part of the gains they have accumulated in this long bull market.
Furthermore, when investors capitulate or begin to move market trends upward again, as the crisis subsides, it is easy to "Un-hedge" accounts and move back to normal allocations. The mistake many advisors and retail investors make is to wait too long to reinvest. Leveraged and inverse products allow prudent tactical moves which are crucial especially in times like these.
All investments involve risk and efforts to protect ignorant or foolish investors, should be done without eliminating the great benefits of leveraged and inverse products.
Proposed Rule #S7-24-15 will throw out the baby with the bathwater
While I value your intent, this rule or any ban, restriction or elimination of these products is unnecessary and damaging to the industry.
Most respectfully I request you drop this approach and move in a less damaging direction.