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David Harkness Comment On Regulatory Notice 22-08

David Harkness
N/A

There is no need for any further regulation of leveraged or inverse ETF's. The risks of these products are widely known and understood by the vast majority of investor. It should be noted that they are no more risky than some of the "penny stocks" or "junk bonds" that currently trade. Despite using leverage, they are often less leveraged than many publicly traded companies. The funds with the largest amount of leverage that aim 3X of the underlying index is still in line or less than the amount of leverage commonly available to real estate investors (putting 20% down on a house would 4X leveraged). Please do not enact any further rules or restrictions of leveraged or inverse exchange traded funds.