Comments: As a retail trader, I find that L&I funds provide adequate exposure to investment instruments of which I am seeking to trade. Traders exposed to these instruments understand and accept the risks L&I funds provide: understanding whether the fund is optioned short or long and as to how much exposure (1x, 2x, 3x). Utilizing these trading instruments are no different than going "short" or "long" on a security and in fact many securities are much more riskier to actively trade on a daily/weekly basis than L&I funds. Our brokers provide adequate warnings regarding inverse funds and expect traders to be properly educated on the instruments they intend to trade. The risk of loss associated with L&I funds is no different than "stocks" where it is up to the trader to determine their bid price and position size - i.e. the monetary loss/gain on 1 share isn't as large as 1000 shares. Most traders understand L&I instruments to be actively traded rather than some sort of long term position. In fact L&I's track a particular future or "bucket" of stocks while not actually holding said securities; they are derivatives, I think we all understand this. Trading the markets is not illegal and I do not believe that L&I instruments available to traders should be banned or curtailed in any way. At the end of the day, it is us the investor responsible for our accounts, their growth, and the responsible use of our capital to achieve account growth and L&I's are part of that tool-box.
Eric Korn Comment On Regulatory Notice 22-08
Comments: As a retail trader, I find that L&I funds provide adequate exposure to investment instruments of which I am seeking to trade. Traders exposed to these instruments understand and accept the risks L&I funds provide: understanding whether the fund is optioned short or long and as to how much exposure (1x, 2x, 3x). Utilizing these trading instruments are no different than going "short" or "long" on a security and in fact many securities are much more riskier to actively trade on a daily/weekly basis than L&I funds. Our brokers provide adequate warnings regarding inverse funds and expect traders to be properly educated on the instruments they intend to trade. The risk of loss associated with L&I funds is no different than "stocks" where it is up to the trader to determine their bid price and position size - i.e. the monetary loss/gain on 1 share isn't as large as 1000 shares. Most traders understand L&I instruments to be actively traded rather than some sort of long term position. In fact L&I's track a particular future or "bucket" of stocks while not actually holding said securities; they are derivatives, I think we all understand this. Trading the markets is not illegal and I do not believe that L&I instruments available to traders should be banned or curtailed in any way. At the end of the day, it is us the investor responsible for our accounts, their growth, and the responsible use of our capital to achieve account growth and L&I's are part of that tool-box.