Comments: I am an investor, an advisor, a father, a son, husband and business owner. I have used these leveraged products in small amounts and I feel there is a lot of warnings, disclaimers, etc on these already. If anything maybe make the warning bigger or more bold but don't limit the access of these. That would in my mind do the following 1-increase risk because it would limit volume and allow fewer people to in some ways "control" the positions 2-Create a burden on the broker, as an advisor the burden is on me to make sure it is not just suitable but as a fiduciary it is the right thing. So I use these very small doses of leveraged to achieve protection, hedges and sometimes additional growth. I could see making sure that brokers aren't recommending them without higher suitability standard sure, but I think most firms are super conservative with these and don't allow recommending them with out approval. 3-We understand that these products are to be used in short term trading and trend following. For example when covid hit these got hit hard but it provided an opportunity for me and my kids to buy a small amount in each of my kids accounts that really proved to be a "life changer" in a short time. Had we lost the money it was less than 5% of their investments, but the growth was so substantial that it ended up being 50% of their account value when we sold. 4-I would imagine this is or will be a big source of tax revenue as well for short term taxes and being taxed at a high rate. I know I got hit hard with taxes but I was happy to pay as I made money. 5-Risk This is what td does as a warning on their retail website Investing in leveraged and inverse exchange-traded products (ETPs) involves heightened risks and is not appropriate for most investors. Leveraged and inverse ETPs seek to deliver multiples of the short-term performance (or the opposite of the performance) of the index or benchmark they track. For most of these products, the amount of leveraged or inverse exposure resets each day. The daily resetting has a compounding effect that can cause these securities to perform worse than their multiple would suggest over any period longer than one day. This effect can be magnified in volatile markets. It is important to remember that most of these securities are designed for daily use only, and are not intended to be held overnight or long term. Learn more about leveraged and inverse ETPs Exchange traded funds (ETFs) are investment companies that trade on an exchange like stock. ETF trades may be placed using any stock order entry ticket. Stock commissions apply. Before investing in an ETF, be sure to carefully consider the ETFs investing objectives, risks, charges and expenses. For a prospectus containing this and other important information, contact the ETF sponsor or a TD Ameritrade Client Services representative. Please read the prospectus carefully before investing. Orders for OTCBB securities are subject to the OTCBB Securities Trading Rules. Extended-hours quotations may be delayed, may reflect only the securities closing price, and may not include information from all extended-hours market participants. Extended-Hours Trading is subject to the Extended-Hours Trading Rules. Execution price, speed and liquidity are affected by many factors, including market volatility, size and type of order and available market centers. Price can change quickly in fast market conditions, resulting in an execution price different from the quote displayed at order entry. We cannot guarantee prices on market orders. In addition, there is the risk that outages involving your access to the Internet or our own systems may interfere with your ability to access your online account. If you experience difficulties, please contact a Client Services representative. My simple suggestion would be if you want to do anything simply require that this wording be in bold or bigger or a simple pop up on all leveraged etfs with a warning but not limit people. Let them learn and attest to learning but not limit investing that could really kill the products which I don't feel is right. If it was something inherently bad about it sure like russia, but to limit trading to certain demographics seems to me like profiling and not giving the same opportunity to those less wealth as you would to the wealth. Which already occurs and clients all the time small ones call and think that because they can't have access because of their wealth, they don't have the education when many times they do. This is one of the few products that an educated younger entrepreneur can start small and build on, no million dollar minimus, no you have to have a certain net worth or earn enough to invest. Fairness at some point needs to be addressed in our world and this would just lead to more inequitable behavior.
Jared Stubbs Comment On Regulatory Notice 22-08
Comments: I am an investor, an advisor, a father, a son, husband and business owner. I have used these leveraged products in small amounts and I feel there is a lot of warnings, disclaimers, etc on these already. If anything maybe make the warning bigger or more bold but don't limit the access of these. That would in my mind do the following 1-increase risk because it would limit volume and allow fewer people to in some ways "control" the positions 2-Create a burden on the broker, as an advisor the burden is on me to make sure it is not just suitable but as a fiduciary it is the right thing. So I use these very small doses of leveraged to achieve protection, hedges and sometimes additional growth. I could see making sure that brokers aren't recommending them without higher suitability standard sure, but I think most firms are super conservative with these and don't allow recommending them with out approval. 3-We understand that these products are to be used in short term trading and trend following. For example when covid hit these got hit hard but it provided an opportunity for me and my kids to buy a small amount in each of my kids accounts that really proved to be a "life changer" in a short time. Had we lost the money it was less than 5% of their investments, but the growth was so substantial that it ended up being 50% of their account value when we sold. 4-I would imagine this is or will be a big source of tax revenue as well for short term taxes and being taxed at a high rate. I know I got hit hard with taxes but I was happy to pay as I made money. 5-Risk This is what td does as a warning on their retail website Investing in leveraged and inverse exchange-traded products (ETPs) involves heightened risks and is not appropriate for most investors. Leveraged and inverse ETPs seek to deliver multiples of the short-term performance (or the opposite of the performance) of the index or benchmark they track. For most of these products, the amount of leveraged or inverse exposure resets each day. The daily resetting has a compounding effect that can cause these securities to perform worse than their multiple would suggest over any period longer than one day. This effect can be magnified in volatile markets. It is important to remember that most of these securities are designed for daily use only, and are not intended to be held overnight or long term. Learn more about leveraged and inverse ETPs Exchange traded funds (ETFs) are investment companies that trade on an exchange like stock. ETF trades may be placed using any stock order entry ticket. Stock commissions apply. Before investing in an ETF, be sure to carefully consider the ETFs investing objectives, risks, charges and expenses. For a prospectus containing this and other important information, contact the ETF sponsor or a TD Ameritrade Client Services representative. Please read the prospectus carefully before investing. Orders for OTCBB securities are subject to the OTCBB Securities Trading Rules. Extended-hours quotations may be delayed, may reflect only the securities closing price, and may not include information from all extended-hours market participants. Extended-Hours Trading is subject to the Extended-Hours Trading Rules. Execution price, speed and liquidity are affected by many factors, including market volatility, size and type of order and available market centers. Price can change quickly in fast market conditions, resulting in an execution price different from the quote displayed at order entry. We cannot guarantee prices on market orders. In addition, there is the risk that outages involving your access to the Internet or our own systems may interfere with your ability to access your online account. If you experience difficulties, please contact a Client Services representative. My simple suggestion would be if you want to do anything simply require that this wording be in bold or bigger or a simple pop up on all leveraged etfs with a warning but not limit people. Let them learn and attest to learning but not limit investing that could really kill the products which I don't feel is right. If it was something inherently bad about it sure like russia, but to limit trading to certain demographics seems to me like profiling and not giving the same opportunity to those less wealth as you would to the wealth. Which already occurs and clients all the time small ones call and think that because they can't have access because of their wealth, they don't have the education when many times they do. This is one of the few products that an educated younger entrepreneur can start small and build on, no million dollar minimus, no you have to have a certain net worth or earn enough to invest. Fairness at some point needs to be addressed in our world and this would just lead to more inequitable behavior.