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Ian McCormick Comment On Regulatory Notice 22-08

Ian McCormick
N/A

Comments:

Regarding inverse and leveraged ETFs: I feel they both are important tools for retail traders, especially novice traders inexperienced with traditional short-selling and options.

Many novice traders lose in the market because they only know how to play it one direction, I.E. buy low sell high. They either don't understand, are intimidated by, or don't want/have the margin account necessary to short. So, with limited options, they trade against, rather than with the trend, often losing. Inverse ETFs offer an introduction to short-selling which is intuitive to novice traders and, more importantly, doesn't require them to trade on margin. For newer traders it opens the door to trading the market both ways in a safer, less unfamiliar, and less risky fashion.

Leveraged ETFs similarly offer returns similar to options trades, with the advantages to novice traders that margin isn't necessary, and though the product isn't meant and shouldn't be held long-term, it is much more forgiving than theta decay and expiration.

Every trade of leveraged and inverse ETFs through my broker comes with a notice of the involved risks, and the trade cannot be completed without acknowledgement of the notice. Furthermore, every trade results in the delivery of the fund prospectus, which also goes into great detail about the unique risks associated with these products. It is my opinion that such forewarning is adequate given that trading these products is very similar to trading common shares of stock.

In summary: Though more complex than common shares of stock, leveraged and inverse ETFs are a great opportunity for and introduction to more advanced trading techniques, and rather than increasing the risk to traders, they actually give newer traders the opportunity to more successfully trade the market using more advanced strategies without the outsized risks involved in true short-selling and options strategies.