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Brian Miller Comment On Regulatory Notice 22-08

Brian Miller
N/A

I am a retail investor and I invest in what might be considered "complex" products such as volatility ETFs and leveraged ETFs. I could simply trade futures contracts and replicate these strategies, however investing in ETFs that maintain those positions is easier. I am aware of the risks of these funds and investigate their strategies carefully before investing. In many cases, I have my own models that simulate the performance of their strategies. Overall, I've done well with these funds and I am satisfied that they are sufficiently regulated. These funds are important to market efficiency and market completion. All investments contain risks, many of these funds are based on indexes and are less risky than holding the common stock of an individual company. For example, the value of Netflix common stock has fallen 70% over the past 6 months. Even holding a long-dated US government bond contains significant economic value risk. As a retail investor, I should be able to chose the investments that fit my risk tolerance when favorable market conditions present.