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Hyon Im Comment On Regulatory Notice 22-08

Hyon Im
N/A

Comments: I fully support unrestricted access to 3x ETFs to individual traders.

However, I would mandate these funds to explain in more detail using real past data to demonstrate

1) how 3x effects occur over multi-days
2) how contango can erode the value and exactly how much erosion is occurring
3) and how often and under what criteria fund holdings are changed

3x funds are great, we just need to improve on explaining the usually not well described details