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Gregory Braden Comment On Regulatory Notice 22-08

Gregory Braden
N/A

Please do not place new restrictions on leveraged or inverse ETFs and traditional mutual funds.

As mutual funds, both ETFs and traditionals are well-regulated and their fee structures are transparent. They are also easy to use through many brokerages.

For an investor who at times wants to use leverage or an inverse position for a short period of time, inverse and leveraged mutual funds are the most convenient way to do so -- compared to, for example, shorting securities or purchasing derivatives (puts) or swaps, which are much more complicated to trade.

So - inverse and leveraged mutual funds (both traditional and ETFs) provide an understandable, transparent, and easy to use mechanism for logical "shorting" or taking a mildly leveraged position. They are a valuable product to have available.