Comments: I BELIEVE ALL INVESTORS SHOULD HAVE ACCESS TO LEVERAGED AND INVERSE ETFS. ALL INFORMATION WHICH HAS BEEN PROVIDED TO ME ABOUT THESE PRODUCTS OVER THE YEARS HAS BEEN VERY CLEAR IN DESCRIBING THE PRODUCTS AND THEIR RISKS. I HAVE RUN THE NUMBERS MANY TIMES USING HISTORICAL DATA AND FIND THAT LEVERAGED PRODUCTS CAN BE HELPFUL AND SOUND INVESTMENTS. TO DISALLOW THE PRODUCTS OR INTRODUCE RESTRICTIONS OR REQUIREMENTS ON THEIR ISSUE AND/OR USE WILL LIKELY RESULT IN PROVIDERS CEASING TO OFFER SUCH PRODUCTS, RESULT IN THE LIQUIDATION OF EXISTING PRODUCTS AND THUS, FURTHER RESULT IN LOSSES FOR MANY INVESTORS WHO ARE HOLDING THESE INVESTMENTS LONG TERM. IF REGULATORY AGENCIES FEEL THEY MUCH DO SOMETHING, THEN LOOK AT INVERSE PRODUCTS AND PERHAPS CURTAIN THE EXTENT OF THE LEVERAGED PRODUCTS SUCH THAT THEY LEVERAGE WILL NOT EXCEED 3X. INTRODUCING RESTRICTIONS THAT WILL EFFECTIVELY BAN THE LEVERAGED PRODUCTS OR RESULT IN INVESTMENT FIRMS NO LONGER OFFERING THESE INVESTMNETS, WOULD BE OVERKILL. MANY THANKS. DALE FISCHER
Dale Fischer Comment On Regulatory Notice 22-08
Comments: I BELIEVE ALL INVESTORS SHOULD HAVE ACCESS TO LEVERAGED AND INVERSE ETFS. ALL INFORMATION WHICH HAS BEEN PROVIDED TO ME ABOUT THESE PRODUCTS OVER THE YEARS HAS BEEN VERY CLEAR IN DESCRIBING THE PRODUCTS AND THEIR RISKS. I HAVE RUN THE NUMBERS MANY TIMES USING HISTORICAL DATA AND FIND THAT LEVERAGED PRODUCTS CAN BE HELPFUL AND SOUND INVESTMENTS. TO DISALLOW THE PRODUCTS OR INTRODUCE RESTRICTIONS OR REQUIREMENTS ON THEIR ISSUE AND/OR USE WILL LIKELY RESULT IN PROVIDERS CEASING TO OFFER SUCH PRODUCTS, RESULT IN THE LIQUIDATION OF EXISTING PRODUCTS AND THUS, FURTHER RESULT IN LOSSES FOR MANY INVESTORS WHO ARE HOLDING THESE INVESTMENTS LONG TERM. IF REGULATORY AGENCIES FEEL THEY MUCH DO SOMETHING, THEN LOOK AT INVERSE PRODUCTS AND PERHAPS CURTAIN THE EXTENT OF THE LEVERAGED PRODUCTS SUCH THAT THEY LEVERAGE WILL NOT EXCEED 3X. INTRODUCING RESTRICTIONS THAT WILL EFFECTIVELY BAN THE LEVERAGED PRODUCTS OR RESULT IN INVESTMENT FIRMS NO LONGER OFFERING THESE INVESTMNETS, WOULD BE OVERKILL. MANY THANKS. DALE FISCHER