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Athene Chan Comment On Regulatory Notice 22-08

Athene Chan
N/A

I should be able to invest in the public investments that are available. There should be not any special process like passing a test before I can invest in public securities.

I use leveraged and inverse funds to hedge my portfolio in volatile market. It is very important to me to have the leveraged and inverse funds available to investors like me. I do not want to sell all the stocks in my portfolio when the market is volatile. Especially with the tax with every sell with profits and the wash sales, I don't want to sell my portfolios every time. My investment is long term and the leveraged and inverse funds are my tools to hedge the market without having to sell my stocks.

Like the current downturn of S&P 500 and Nasdaq (April 2022), I bought SPXU and SQQQ to hedge my portfolio. The 3x leverage allows me to hedge my portfolio without a lot of capital which is tied up in my stock portfolio. Without these tools, I may have to sell stocks and buy them back later, which creates tax liabilities and may be even wash sales which I cannot deduct in my tax return as a loss.

The leveraged and inverse funds should be treated like regular securities. If I have the right to buy stocks without restrictions, I should have the right to buy leveraged and inverse funds without restrictions.

Thank you for reviewing my comment!