Comments: Please allow retail investors access to leveraged funds and ETFs as small exposure can be part of an important part of investment strategy such as hedging. If the position size is small (small percentage of portfolio) then the overall risk exposure to any of these funds can never be too great. Certain sectors (micro caps) can be as risky (if f not more so) than leveraged funds in my opinion. Finally, the access to leveraged funds has been allowed for many years without great losses (speaking of my account), so empirically I have managed any risk pretty well thus far. I implore you to allow access of retail investors to the full range of leveraged products. Its true that some strange things can happen (like the time oil was priced negatively) but in the end a very small position with stop loss orders entered should be permitted. Thanks for your consideration in these matters.
Donald Schultz Comment On Regulatory Notice 22-08
Comments: Please allow retail investors access to leveraged funds and ETFs as small exposure can be part of an important part of investment strategy such as hedging. If the position size is small (small percentage of portfolio) then the overall risk exposure to any of these funds can never be too great. Certain sectors (micro caps) can be as risky (if f not more so) than leveraged funds in my opinion. Finally, the access to leveraged funds has been allowed for many years without great losses (speaking of my account), so empirically I have managed any risk pretty well thus far. I implore you to allow access of retail investors to the full range of leveraged products. Its true that some strange things can happen (like the time oil was priced negatively) but in the end a very small position with stop loss orders entered should be permitted. Thanks for your consideration in these matters.