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Alison Szeto Comment On Regulatory Notice 22-08

ALISON SZETO
N/A

I should be able to choose the public investments that are right for me and my family. Leveraged and inverse funds are important to our investment strategies. Leveraged etfs will run well with enhanced return if the trend is up whereas inverse ETFs help to protect our investments during market correction and downtrend. Hence, public investments, especially hedging, should be available to all of the public, not just the privileged and wealthy ones. Investment is for long term in the broad market indices. From 1931 to 1971, stock equities appreciate 450%. From 1971 to 2019, stock equities appreciate 3100%. From 2019 to 2021, QQQ is up 113.65%, SPY up 75.96%, DIA up 58.47%. From 1931 to 2021 US experienced many recessions with length from 8 months to 18 months. But US broad markets weather these storms and head north. As of 5/4/2022, returns of Nasdaq ETF (QQQ) for ytd is -20.63%, 1 yr -4.88% , 2 yr 48.14%, 3 yr 67.85%, 5 yr 132.45%, 10 yr 394.14% whereas return for the 3x leveraged (TQQQ) for YTD is -55/19%, 1 YR is -27.59%, , 2 yr 133.21%, 3 yr 131.1%, 5 yr 372.17%, 10 yr 3647.80%. In long term perspective, US broad markets trend upward with some setbacks in between. One of the reasons is we have very profitable growth stocks in the technical, Ecommerce, and semiconductor sectors like Apple, Google, Microsoft, Facebook, Amazon, Tesla, Nvidia, AMD etc in the broad markets with net profit margin ranging from 10-40% plus. Long term investment in US broad markets is a success. Investments into the large or mega caps in long term will increase our asset values and the leveraged ones produce more sound results. For 10 years investment return, it is 394.14% in QQQ versus 3647.80% in TQQQ. Taking the leveraged funds investments away from the public and giving those to the hands of wealthy investors only are discriminating non wealthy investors. This will create a bigger gap between the wealthy and the poor. Currently, broad markets are in correction due to pandemic leading to supply chain issues and inflation, China lock down, Feds tightening monetary policy to hike interest rate and Quantitative Tapering so as to combat inflation, fear of recession, and geopolitical turmoil caused by Russian invasion of Ukraine. Growth stocks with good fundamentals suffer too. We are seeing 10-40% drop in individual stocks, not to mention the leveraged ETFS. An article from WSJ.COM on April 10 titled Six reasons why stocks are rallying shows Average index performance following first Fed rate hike of 1994 through 2015. All indices dip hard in first month after first Fed rate hike, and then resumes to level at first Fed rate hike date by 3 Month. In a year after first Fed rate hike, Dow Jones, S&P, and Nasdaq are in gain of mid single digit to close to 20% return. Now we have hiccups. The YTD and 1 YR returns for Nasdaq QQQ as well as its leveraged counterpart TQQQ are in losses. Given time, the stock markets will come back. Taking leveraged ETFS investing into broad markets during broad market correction and downturn away from public investors means to force us to take loss when we can wait for profitable results from long term investments. Since broad markets trend up in long term, their corresponding inverse funds are for short term protection only. Investors need to do research on their own. If they dont know, they should seek professional help. Cutting loss at what time should be decision and responsibility of individual investors depending on their risk tolerance level. The leveraged and inverse funds should be available for public investments.