March 23, 2020
To whom it may concern:
I have been utilizing leveraged and inverse ProFunds for over 20 years. I've done so without bankrupting myself. In fact, I have developed a trading model which, using these fund types, enables me to seek reasonable returns with a reduced risk profile. Additionally, I have recently used inverse ProFunds to hedge the exposure of long term holdings that I didn't which to sell. This allowed me to effectively protect the value of my portfolio during the recent period of market duress.
The basic premise of inverse and leveraged funds is quite rudimentary - easily understood by any reasonably competent investor. The funds themselves are less risky than a common stock, as they bear no company-specific risk. As such, it is easier to achieve catastrophic financial loss by buying an individual stock than one of the funds in question. Equity investors are not subject to a third party assessment of their financial acumen prior to making stock purchases. Yet, there is now a proposal to perform an assessment of individuals who wish to purchase instruments carrying LESS INHERENT RISK. This conflict underscores a very reasonable conclusion that the proposal in question is poorly conceived. In this specific case, there is no legitimate reason to restrict investors from making calculated choices within their portfolios.
As an educated, non-professional investor, I firmly believe in "leveling the playing field" of the financial marketplace. The proposed restrictions upon individual investors would move the needle in the opposite direction, to the detriment of these investors.
Thank you for your consideration.