April 9, 2020
I am writing to urge you not to implement regulations that would increase the burden on managers who wish to use leveraged or inverse funds. Such funds serve a valid purpose, either as hedges or as a vehicle to establish exposure to a market quickly while minimizing how much of a client's cash is tied up. As fiduciaries with discretion over our clients' funds, our own experience is what's relevant, not the client's. That's why they have us. If they are limited to simplistic vehicles, their experience may be sub-optimal.