I should be able to choose investments that I deem appropriate for me. I primarily use inverse funds to hedge my fixed income portfolio. This enables me to collect interest on my investments while limiting downside exposure to my principal in a rising rate environment. Not having the ability to do so would unnecessarily cost me loss of principal. In addition, I also use inverse treasury funds as an investment in times of rising interest rates such as now. I don't see any greater risk in that than buying Treasury notes. With T notes, I make money when rates go down and lose money when rates rise. An inverse fund allows me to take the opposite side of this trade. The risk is basically the same. When the Federal Reserve is raising rates as in the current economic environment owning bonds and notes poses risk. Conversely, in that environment there is minimal risk of losing money in an inverse Treasury ETF. You would be doing a great disservice to investors by limiting their ability to use inverse funds.
Fred Saunders Comment On Regulatory Notice 22-08
I should be able to choose investments that I deem appropriate for me. I primarily use inverse funds to hedge my fixed income portfolio. This enables me to collect interest on my investments while limiting downside exposure to my principal in a rising rate environment. Not having the ability to do so would unnecessarily cost me loss of principal. In addition, I also use inverse treasury funds as an investment in times of rising interest rates such as now. I don't see any greater risk in that than buying Treasury notes. With T notes, I make money when rates go down and lose money when rates rise. An inverse fund allows me to take the opposite side of this trade. The risk is basically the same. When the Federal Reserve is raising rates as in the current economic environment owning bonds and notes poses risk. Conversely, in that environment there is minimal risk of losing money in an inverse Treasury ETF. You would be doing a great disservice to investors by limiting their ability to use inverse funds.