March 25, 2020
This rule is bad for investors, unnecessary, and sets a dangerous precedent. As an investor of leveraged funds, I have done an enormous amount of research and find them to be the ideal investment vehicle consistent with my investing goals. I have a PhD, teach statistics, and have spent years developing an investing model centered around leveraged ETFs. I am very qualified intellectually to invest in these finds, and cannot think of any appropriate rationale that the SEC could use to subjectively evaluate my ability to comprehend the underlying statistics as well as my own personal tolerance for risk versus reward. Having the SEC evaluate my ability as investor sets a precedent that makes me greatly question the integrity of the SEC. Will you use criteria like years of experience, amount of money invested, age of account, academic level, personal vs. corporate investor, etc.? I could see reasoning why all of these could contribute to bias in the type of investor that is approved to invest in these funds. Ultimately, this prevents free market investing and could potentially be seen as an effort to suppress the ability of certain social demographics to gain wealth through investing. This type of ruling pits the "haves" versus the "have nots". It would a terrible investing environment in the United States if this type of ruling got out of control. It is not the purpose of the SEC to control who should invest and who should not. I strongly oppose rule #S7-24-15.