Skip to main content

Charles Bank Comment On Regulatory Notice 22-08

Charles Bank
N/A

To whom it may concern,

I am a retail investor with over 20 years of investment experience. I am a software engineer, and generally a nerd that tries to built expertise in anything I have interest in.

I understand the risks involved in the use of leveraged funds, and they are vital to some of the strategies I employ. One of my strongest portfolios is currently based on Ray Dalio's All Weater portfolio, a risk parity strategy that I have adjusted to scale risk through use of leverage. While less than 30% of the portfolio is using leveraged ETFs, I would not be able to adjust risk to match my target without those funds. This portfolio has outperformed the market while suffering lower drawdowns than the S&P 500.

Regardless of additional tests and regulation on this specific set of funds, fools and their money will continue to part. Unless these funds are somehow misrepresenting their risk profiles to retail investors, they should not be restricted from us. We should be assumed to be responsible enough to make our own financial decisions.

I hope you will consider this when making a decision whether to restrict my right to invest.