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Andrey Tytchino Comment On Regulatory Notice 22-08

Andrey Tytchino
N/A

While it may seem reasonable and prudent to limit access to leveraged ETFs to novice traders, experienced traders with 2 years of experience or more, should be able to enjoy the full and unrestricted freedom of trading such instruments. However, the following measures should be implemented: -Restrict the trading of all leveraged ETFs to accounts with balances under $10 000 USD for traders with under 5 years of experience -Restrict trading of leveraged ETFs to all traders with less than 2 years of trading experience -Make all traders sign a waiver, stating that they understand the dangers of trading the 3x ETFs, and how the instrument can overexaggerate both losses and gains. -With respect to index-linked leveraged ETFs, make a waiver available to traders with under two years of experience, and allow trading index-linked leveraged ETFs in such a way that no more than 33% of account size can be allocated to one single index-linked ETF -Restrict the short sale of inverse leveraged ETFs to traders with less than 2 years of experience, and restrict naked short calls on these instruments. -Disallow any margin utilization on triple leveraged ETS for traders with less than 5 years of experience. I hope these recommendations will improve the safety and security of the financial future of the new and experienced traders.