March 20, 2020
I have read the Summary and Supplemental Information regarding this action. With respect to- "The proposed sales practices rules would require a broker, dealer, or
investment adviser that is registered with (or required to be registered with) the Commission to
exercise due diligence in approving a retail customers or clients account to buy or sell shares of
certain leveraged/inverse investment vehicles before accepting an order from, or placing an
order for, the customer or client to engage in these transactions," I did not see the requirements for 'due diligence' on the part of the adviser or reporting requirements on the part of the investor. I understand from other sources this may be a prohibitive process. However, it makes little difference what they are.
To reduce, eliminate or hinder access to leveraged/ inverse investment vehicles would be wrong on the part of a governing body. This action should not only be avoided but prohibited instead of proposed.
Consider this- would a home builder sooner use a shovel or excavator to dig a foundation? Would a builder sooner use a handsaw or powered circular saw to cut his lumber? A lumberjack- an axe or chainsaw? These powerful tools require no special requirements to buy or use and are found on every corner of this great country. They do require some training, knowledge, caution and intelligence. The user gets this on his own either through use or asking a friend/ family member. Leveraged/ inverse investment vehicles are no different and should be treated as such. To remove the liberties and freedoms of an investor in this way is wrong on every level. To be clear, an investor should not be able to invest in a way that harms the market or society. In turn, no governing body should prohibit in any way the access of an investor to vehicles which do not do so.