My investment strategy uses a systematic rebalancing of ETFs, some of which are leveraged ETFs. I fully understand the risks of these leveraged ETFs, but with a disciplined quarterly plan of selling when gains have exceeded a threshold and buying when losses have exceeded a threshold, the greater volatility of these leveraged ETFs produce better performance over the long term.
I am not a Day trader and 40 years of investing has taught me that in the short term the stock market is emotional and unpredictable, but that over time it rises more than it falls. A disciplined investor can use this market behavior very effectively with both leveraged and non-leveraged ETFs.
I do not need or want a third party evaluating my capability of using leveraged ETFs and frankly do not trust that the criteria that would be established to evaluate investors capabilities would not result in these instruments be confined to extremely wealthy investors or investment professionals only. This is not fair to those who fully understand the risks and assume the responsibility for their decisions and could exacerbate the wealth Gap.
Please keep leveraged funds available to all investors.
David DeSousa Comment On Regulatory Notice 22-08
My investment strategy uses a systematic rebalancing of ETFs, some of which are leveraged ETFs. I fully understand the risks of these leveraged ETFs, but with a disciplined quarterly plan of selling when gains have exceeded a threshold and buying when losses have exceeded a threshold, the greater volatility of these leveraged ETFs produce better performance over the long term.
I am not a Day trader and 40 years of investing has taught me that in the short term the stock market is emotional and unpredictable, but that over time it rises more than it falls. A disciplined investor can use this market behavior very effectively with both leveraged and non-leveraged ETFs.
I do not need or want a third party evaluating my capability of using leveraged ETFs and frankly do not trust that the criteria that would be established to evaluate investors capabilities would not result in these instruments be confined to extremely wealthy investors or investment professionals only. This is not fair to those who fully understand the risks and assume the responsibility for their decisions and could exacerbate the wealth Gap.
Please keep leveraged funds available to all investors.