May 10, 2020
Item 1: General Identifying Information
a. Is the firm a Commission-registered investment adviser or a broker-dealer?: No, I am an individual investor
b. What is the size of the firm in terms of:
1.) The number of retail investors (as defined in the release)?
2.) For Investment Advisers, regulatory assets under management?
3.) For broker-dealers, regulatory net capital?
4.) Other (please specify)? NA
c. Please include any additional general identifying information that you wish to provide, that could add context to your other feedback on the proposal.
As a private investor I have been investing in leveraged funds for the last few years. They are not difficult to understand.
d. Does the firm accept orders from or place orders for the accounts of retail investors to buy or sell shares of leveraged/inverse investment vehicles (as defined in the proposed sales practices rules)?
NA
Item 2: Cost to Comply with the Proposed Due Diligence and Account Approval Requirements
a. What do you expect the cost to your firm would be in order to comply with these proposed requirements (in terms of combined internal and external costs)?
1.) For an investment adviser (check one box):
2.) For a broker-dealer (check one box):
b. Are there any less expensive alternatives to the proposed requirements you can suggest that would still preserve the proposed rules intended investor protection safeguards?
NA
Item 3: Other Feedback on Proposed Sales Practices Rules
Instructions: Please include any other additional suggestions or comments about the proposed sales practices rules that you would like to provide.
I would not appreciate ANY additional restrictions on the ability of an individual investor to trade these funds. As they say, all investments have risks and individual investors should study investments before investing. The principle that leveraging works both ways should not be hard to understand. Thank you for considering this feedback.