I use inverse bond funds as a speculative tool to profit from a rise in interest rates just like someone who would sell bond futures short. Trading bond futures is more leveraged and riskier than what I am doing so why would you limit what I am doing but not restrict bond futures trading as well. There is no logic to that. I am asking you to NOT take my right to buy and hold inverse and leveraged funds away from me. To do that and continue to let people trade higher leveraged futures contracts would not be fair. In fact, you would be pushing people like me to trade futures as an alternative. Something way more riskier which involves perfect timing instead of the buy and hold strategy that I use for exchange traded funds. Thank you for your consideration.
Eric Robin Comment On Regulatory Notice 22-08
I use inverse bond funds as a speculative tool to profit from a rise in interest rates just like someone who would sell bond futures short. Trading bond futures is more leveraged and riskier than what I am doing so why would you limit what I am doing but not restrict bond futures trading as well. There is no logic to that. I am asking you to NOT take my right to buy and hold inverse and leveraged funds away from me. To do that and continue to let people trade higher leveraged futures contracts would not be fair. In fact, you would be pushing people like me to trade futures as an alternative. Something way more riskier which involves perfect timing instead of the buy and hold strategy that I use for exchange traded funds. Thank you for your consideration.