March 20, 2020
To the SEC:
Your proposed regulations concerning leveraged and inverse funds was brought to my attention. Upon looking into this matter, I must express my most strident and vociferous opposition to your proposed regulations.
Leveraged and/or inverse funds have been a staple asset in my investment portfolio and my ability to invest/trade in them has benefited me substantially. Your proposed regulations would likely impact my ability to invest/trade in leveraged/inverse funds, and thus hamper my ability to optimally manage and grow my portfolio. Your proposed regulations will result in limiting access, place more impediments to investing/trading in leveraged/inverse funds, and simply put, make investing more difficult.
And to what end? Investing should be the domain and business of the investor alone, and NO THIRD PARTY, even the SEC, should interfere with one's investment decisions. Investors should know, and do know, the inherent risks and rewards to investing in any type of investment, and it is NOT UP TO ANY THIRD PARTY, even the SEC, to meddle in any investor's risk-reward calculation. Investors should have the FREEDOM to make their own investment decisions, and by the same token, be left responsible for their own decisions. The SEC has absolutely NO place in that domain, and should NOT be inserting itself in these very individual, case-specific decisions.
It might be worth reminding you that the SEC's job is to prevent fraud in the markets and facilitate information symmetry between counterparties to the extent possible. Your proposed regulations on leveraged/inverse funds is well-outside that purview, and is a flagrant over-reach. There is no fraud involved with leverage/inverse, and your proposed regulations have nothing to do at all with promoting information symmetry in the markets.
One more point: your proposed regulations on leveraged/inverse funds has already caused a lot of unwarranted uncertainty and wasted time. The unwarranted uncertainty comes from the uncertain future around investing in leveraged/funds, which as you well know, complicates decision-making and depresses economic value. This is all unwarranted because there is NO GOOD REASON you, the SEC, should have been proposing this in the first place. There are other more worthwhile endeavors for you to focus your energies on (i.e., cracking down on fraud/ponzi schemes, etc.), and targeting leveraged/inverse funds is akin to law enforcement foolishly looking into cracking down on innocuous, legal behaviors. Additionally, this has been a waste of time because now busy investors like myself have to take the time and trouble to weigh in and get involved in a discussion that is unnecessary in the first place. I hope you understand the trouble your proposed regulations on leveraged/inverse funds is already causing today Going forward, please take into account ALL consequences before taking any action - a powerful and far-reaching agency like the SEC has to hold itself up to a much higher, even impeccable, standard of judgment and discretion.
To close, I strongly urge you to drop your proposed regulations around leveraged and inverse funds. I look forward to you, the SEC, acting in investors' best interests - which is to keep the way things are - for all the reasons, and perhaps more, articulated in this message.