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Charles Royce Comment On Regulatory Notice 22-08

Charles Royce
N/A

This is not the first time that regulators have attempted to regulate Leveraged ETFs.

For some reason, we only see these actions at times when the markets have increased volitility. When times are good and the leveraged long ETFs are soaring, there is no scrutiny. Only when the leveraged short ETFs can provide value to investors do we see the risk of regulation or curtailing.

I consider a leveraged ETF to be an important vehicle that should not be reserved for wall-street specialists or elites who have inside relationships. The ability to judiciously use these vehicles at specific times as part of a deliberate investment strategy usually when there is strong market momentum is helpful to investors. These ETFs often provide public investors the ability to create long short strategies that otherwise they would not be able to do otherwise.

FINRA and the SEC are encouraged to reconsider any action to regulate or curtail use of these investment products.