March 22, 2020
Item 1: General Identifying Information
a. Is the firm a Commission-registered investment adviser or a broker-dealer?: No
b. What is the size of the firm in terms of:
1.) The number of retail investors (as defined in the release)? 0
2.) For Investment Advisers, regulatory assets under management? 0
3.) For broker-dealers, regulatory net capital? 0
4.) Other (please specify)? 1 Myself
c. Please include any additional general identifying information that you wish to provide, that could add context to your other feedback on the proposal.
I use leveraged ETFs to provide diversification in my portfolio. Using these allows me to do more with less so I can buy conservative instruments. These ETFs are allowing me to achieve the American dream that I do not believe should just be reserved for accredited investors. The world is going through troubling times and I want to buy bonds that the government will have to issue to fight the war, but I also want to fully participate in the recovery of the markets and using leveraged ETFs will allow me to do just that. I know I am not alone in this belief and investing style. At a minimum I would ask to be grandfathered into being able to continue to use of these funds. Thank You
d. Does the firm accept orders from or place orders for the accounts of retail investors to buy or sell shares of leveraged/inverse investment vehicles (as defined in the proposed sales practices rules)?
Item 2: Cost to Comply with the Proposed Due Diligence and Account Approval Requirements
a. What do you expect the cost to your firm would be in order to comply with these proposed requirements (in terms of combined internal and external costs)?
1.) For an investment adviser (check one box): $0 - $5,000
2.) For a broker-dealer (check one box): $0 - $25,000
b. Are there any less expensive alternatives to the proposed requirements you can suggest that would still preserve the proposed rules intended investor protection safeguards?
An investor questionnaire may be helpful but again not limiting use to just accredited investors.
Item 3: Other Feedback on Proposed Sales Practices Rules
Instructions: Please include any other additional suggestions or comments about the proposed sales practices rules that you would like to provide.