May 4, 2020
I am a veteran 21 year tenure Wealth Management Advisor with Merrill Lynch. I am not an order-taker. I am a certified Senior Portfolio Manager, authorized by my firm to manage portfolios for other Advisors their clients. This proposed rule would harm Americans and result in less choice. This proposed rule further exacerbates our ability to serve our clients, in their pursuit of their financial goals and reduces our capacity to provide them with peace of mind. Our system is currently broken, only in the sense that regulators have shared their opinion that leveraged investments are not good long-term investments have discouraged financial service firms from offering leveraged ETFs. These investments ARE, in fact, best suited for long term investing. I have a client that learned of them in 2009 we began employing them for him his family. He is a CIMA a highly-seasoned investor. Components of his portfolio are up over 3000%. We dont have all of his investments allocated to leveraged ETFs, but they do play a part in a DIVERSIFIED portfolio. Id be happy to testify more on this subject. Do not move forward with more regulation. Its not needed. Instead, if you do anything, propose, for instance, that investors have no more than 50% of their overall portfolio in leveraged ETFs. Leveraged ETFs can play a role in a well-diversified portfolio. If you do anything, propose, for instance, that investors have no more than 50% of their overall holdings in leveraged ETFs.