Skip to main content

Derek Jerina Comment On Regulatory Notice 22-08

Derek Jerina
N/A

I am angry to learn about potential limits of my ability to trade any public security. Leveraged and inverse funds allow me to better manage risks and liquidity in my portfolio. They also offer the ability to trade in smaller sizes than typical futures contracts. Being able to short something without having to adjust exposure daily is a massive benefit for investors. You can't naked short something without worrying as the price goes up that the position is getting too big. Requires constant monitoring. However, geared long and particularly short funds do this automatically. Yes, doing that results in a decay in value due to realized volatility, but your potential maximum loss is known and fixed. The only other way to short with loses capped is to use options and they also suffer from time decay based on implied not realized volatility. You let people trade options... You will create an uneven playing field for investors by restricting access. Additionally, you would reduce liquidity by doing so and excluding retail investors.