I am a small investor who took an interest in ETF investments back in 2008, when a severe drop in the market had affected a great many people. At that time I reasoned that having the ability to engage the market in both directions, UP or DOWN, would be a critical component of my investment strategy. Since then I have employed both conservative and less risk-adverse strategies in my investing - one of those being the use of ETFs and 2x ETFs and reverse ETFs...some that are still in my portfolio.
Recently, I have been made aware by my investment platforms that a certain regulation under consideration is expected to be significantly restrictive to the pool of potential buyers of such funds, which would have a negative impact on the ability of this previously unrestricted market to trade shares. Such interference with an established trading category is onerous to those who are already established in it and completely counter to the principles of our free market financial system. These are public investments that should continue to be traded publicly.
Establishing a "special process" of tests and other criteria prior to being "allowed" to trade assumes that the buyers are mostly too stupid to be left to their own devices and therefore must be protected from themselves. We don't need the results of such a philosophy forced upon us! For those of us who understand market cycles and technical theory it goes beyond just being an impediment to buy that will screw up the ability to time our moves, but potentially shrinks the pool of buyers whereby our reverse direction shares may loose value simply by not having enough people in the market to buy them. We count on you as interested servants of the greater good to consider all aspects of it, not just a minority of disgruntled voices, and do the right thing for everyone involved in the market.
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Gregory Brown Comment On Regulatory Notice 22-08
Dear FINRA Regulators,
I am a small investor who took an interest in ETF investments back in 2008, when a severe drop in the market had affected a great many people. At that time I reasoned that having the ability to engage the market in both directions, UP or DOWN, would be a critical component of my investment strategy. Since then I have employed both conservative and less risk-adverse strategies in my investing - one of those being the use of ETFs and 2x ETFs and reverse ETFs...some that are still in my portfolio.
Recently, I have been made aware by my investment platforms that a certain regulation under consideration is expected to be significantly restrictive to the pool of potential buyers of such funds, which would have a negative impact on the ability of this previously unrestricted market to trade shares. Such interference with an established trading category is onerous to those who are already established in it and completely counter to the principles of our free market financial system. These are public investments that should continue to be traded publicly.
Establishing a "special process" of tests and other criteria prior to being "allowed" to trade assumes that the buyers are mostly too stupid to be left to their own devices and therefore must be protected from themselves. We don't need the results of such a philosophy forced upon us! For those of us who understand market cycles and technical theory it goes beyond just being an impediment to buy that will screw up the ability to time our moves, but potentially shrinks the pool of buyers whereby our reverse direction shares may loose value simply by not having enough people in the market to buy them. We count on you as interested servants of the greater good to consider all aspects of it, not just a minority of disgruntled voices, and do the right thing for everyone involved in the market.
Sincerely, Gregory Brown