I am a Series 7 & 66 holder, as well as a CFP. While I do not typically recommend leveraged or inverse funds for clients, I do use these funds personally and know other investors who do as well. They are high risk, but our brokerages issue required reading before allowing us to invest in these funds. I understand the risks of these funds and strongly desire to continue to use them as a tactical investments for a small percentage of my portfolio. I was a teacher for many years and my personal retirement funds are still lagging from my state's minimal salary and contributions. These leveraged and inverse funds have been an invaluable part of me beginning to make up ground and losing access to these funds would place me at a disadvantage going forward. On a philosophical level, so long as the fund providers (such as ProShares) are not engaged in fraud or deceptive practices regarding the funds in question then it is not the business of any regulatory agency how I choose to invest my personal funds. FINRA and other regulatory agencies should indeed guard against abuse, but the funds in question, though high risk, do not fall into that category.
Craig Callon Comment On Regulatory Notice 22-08
I am a Series 7 & 66 holder, as well as a CFP. While I do not typically recommend leveraged or inverse funds for clients, I do use these funds personally and know other investors who do as well. They are high risk, but our brokerages issue required reading before allowing us to invest in these funds. I understand the risks of these funds and strongly desire to continue to use them as a tactical investments for a small percentage of my portfolio. I was a teacher for many years and my personal retirement funds are still lagging from my state's minimal salary and contributions. These leveraged and inverse funds have been an invaluable part of me beginning to make up ground and losing access to these funds would place me at a disadvantage going forward. On a philosophical level, so long as the fund providers (such as ProShares) are not engaged in fraud or deceptive practices regarding the funds in question then it is not the business of any regulatory agency how I choose to invest my personal funds. FINRA and other regulatory agencies should indeed guard against abuse, but the funds in question, though high risk, do not fall into that category.