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Ian Akehurst Comment On Regulatory Notice 22-08

Ian Akehurst
N/A

I see restricting access to the different types of investment products as overbearing and manipulative of market forces.

The use of inverse and leverage funds are an important market access for all people in the country, for a variety of purposes. They should not be a core part of a portfolio, but do serve a place in building a well-balanced financial plan.

For example, if I am looking to purchase a house and am worried about interest rates rising and increasing mortgage costs, I should be able in invest a small portion of my portfolio in a leveraged inverse treasury bond fund to allow me to remain market-neutral on interest rate changes.

Similarly, you allow consumers to purchase heating oil from vendors that offer year long "price locks", but an alternative would be for me to invest a small amount in a leveraged oil fund to offset potential increases from a flexible purchase arrangement.

If I purchase a large amount of stock and want to insure it through a leveraged volatility ETF and participate in tail-risk hedging, I should have the option to do so without constraint.

These are investment options that should be available to all market participants, not just the few that meet an arbitrary qualification criteria. Everyone should be able to invest, offset risk, and potential benefit from these types of investments.

By limiting the range of products that people can access you risk forcing people to be overly exposed to potential market downturns, and only a subset of elite investors being able to take advantage of those trends.