May 4, 2020
Regarding the SEC inquiry into investor suitability for investment in leveraged and inverse ETFs, according to SEC Release No. 34-87607, dated November 25, 2019, my comment is first and foremost that the SEC must not confuse the size of an individual account with the knowledge and experience of an individual investor and their right to chose among all means available to achieve their chosen investment themes.
Having directly invested in the stock market on my own behalf for more than 30 years, as well as for my family accounts and for accounts of other clients, I can state forcefully that I view leveraged and reverse ETFs as an indespensable tool for all equity investment accounts, whether they are margin accounts, cash accounts, income oriented accounts or actively traded accounts.
The benefits of leveraged and reverse ETFs are many. These include:
Liquidity equal to any equity position
Ease of Access through online brokers
Certainty of Outcome based on clearly defined investment process
Ability to convert a short strategy to a cash account as a long position
Income, as many of these ETFs pay dividends
Low transaction cost
Diversification for portfolios that are otherwise focused on long term single equity choices
Leverage, as most ETFs are marginable.
In short, ETFs have become an indespensable tool for individual investors for all types of accounts.
Publicly traded ETFs I have used successfully include:
Equity index funds such as Invesco QQQ Trust, ProShares Short Dow 30 and ProShares Short SP 500,
Volatility ETFs such as ProShares VIX Short Term Futures and iPath SP 500 VIX Short Term Futures,
Commodity ETFs such as Invesco DB Agriculture, Teucrium Corn Fund, ProShares Ultra Gold, United States Brent Oil Fund and ProShares Short Oil Gas.
Prior to the availability of the leveraged and inverse ETFs offered by Pro Shares and other ETF managers, investors faced far more daunting circumstances. It would have been impossible to achieve such good hedges as those offered by ETFs without introducing portfolio exposure to expensive and inherently more risky options strategies.
Whether the objective on any ETF choice is to achieve a long term gain or to hedge
other portfolio exposures, the ability to execute the trade with all the same rules as a long or short position in any type of a brokerage account makes these ETFs universally applicable.
I trust the SEC is sufficiently sophisticated to understand the benefit of these leveraged and inverse ETFs, and not to take any measures that would limit access for all investors.