I strongly oppose this proposed rule. Having managed my own investments for years, I am well aware of the dangers and potential benefits of leveraged and inverse funds. They have been an important part of my investment portfolio for years. I choose to manage my own risk subject to my own investing objectives, and deeply oppose the government regulators trying to manage them for me and others through this rule. I oppose the suggestion for any rules and barriers to limit and control who can invest in these funds. Leveraged funds have helped me and others take optimal advantage of rising markets. While risk is increased by the leverage, it is also reduced by the fact that the fund contains multiple stocks, and the increased risk of an individual stock is avoided. Inverse funds, leveraged or not, provide a simple means for taking advantage of bear markets. Consider the extended bear markets from Jan, 2000 thru Mar, 2003, from Oct, 2007 thru Mar, 2009, the sharp one-mo Covid drop in Feb and Mar of 2020, and what we're experiencing now since Nov 2021. Yes, timing the beginning and end of these markets is not trivial, but even a prudently managed account can include inverse funds to see gains rather than losses, and the risk of these funds is lower than that of options or of shorting individual stocks. Please do NOT pass this regulation. Our country is founded on the idea of freedom and of the individual's right to make his own decisions as long as they do not harm other people. Our nation has grown to what it is today by the contributions of entrepreneurial individuals taking the measured risks to pursue their ideas, inventions, etc. This proposed regulation files in face of our founding principles and our history of success and growth. Please do NOT put it into effect.
Curtis Miller Comment On Regulatory Notice 22-08
I strongly oppose this proposed rule. Having managed my own investments for years, I am well aware of the dangers and potential benefits of leveraged and inverse funds. They have been an important part of my investment portfolio for years. I choose to manage my own risk subject to my own investing objectives, and deeply oppose the government regulators trying to manage them for me and others through this rule. I oppose the suggestion for any rules and barriers to limit and control who can invest in these funds. Leveraged funds have helped me and others take optimal advantage of rising markets. While risk is increased by the leverage, it is also reduced by the fact that the fund contains multiple stocks, and the increased risk of an individual stock is avoided. Inverse funds, leveraged or not, provide a simple means for taking advantage of bear markets. Consider the extended bear markets from Jan, 2000 thru Mar, 2003, from Oct, 2007 thru Mar, 2009, the sharp one-mo Covid drop in Feb and Mar of 2020, and what we're experiencing now since Nov 2021. Yes, timing the beginning and end of these markets is not trivial, but even a prudently managed account can include inverse funds to see gains rather than losses, and the risk of these funds is lower than that of options or of shorting individual stocks. Please do NOT pass this regulation. Our country is founded on the idea of freedom and of the individual's right to make his own decisions as long as they do not harm other people. Our nation has grown to what it is today by the contributions of entrepreneurial individuals taking the measured risks to pursue their ideas, inventions, etc. This proposed regulation files in face of our founding principles and our history of success and growth. Please do NOT put it into effect.