March 28, 2020
I have utilized leveraged mutual and ETF funds in one of my IRA portfolios for over 10 years now and I strongly believe that I have been successful in enhancing my rate of return during certain market cycles. Although I do have significant retirement assets, I would likely not be considered an accredited investor. I have been investing, primarily through mutual funds, since the early 1970s. My portfolios have suffered both gains and losses at various times and I believe I know the risks involved in managing investments.
I consider leveraged funds to be an important diversification tool and a viable alternative during certain investment cycles and the thought of having to provide extensive personal financial information to the SEC or some other government entity - and then wait for some arbitrary approval (or disapproval) - is a serious infraction and limitation of my freedom to invest as I determine may be best for my particular situation. We already have enough government rules and regulations to provide various protections and extensive disclosures that I believe it is unnecessary to take away the rights of many investors because a few have abused the use of certain equity products or were ignorant of their investment characteristics. I believe most investors know to limit their exposure to higher-risk equity products and invest responsibly.
Whether an individual manages his or her own investments (like I do) or utilizes advisors to help them evaluate the risks of different investments, the freedom to choose investments that best relate to an individual's risk tolerance is an extremely important right that investors have enjoyed for nearly 100 years and I do not believe there is any justification to restrict that right just because certain investments contain more risks than others.
I am strongly requesting that the SEC not limit the use of leveraged funds to only certain qualified or approved investors. Regardless of the size of one's portfolio, my belief is that all investors need to have access to all publicly available securities.
An alternative to investors having to prove their qualifications in order to purchase leveraged funds, might be to require these fund managers to place highly visible disclosures and or warnings in large print on the front of prospectuses and other sales material.
Thank you for your consideration.