Comments: inverse ETFs: investors with small accounts and limited knowledge or no access to options have no way to hedge their position without inverse ETFs. Putting small retail at that kind of disadvantage exposes them to more risk and potential losses. It forces them into trying to time getting out of the market, and/or taking gains in the short term bracket instead of holding and hedging and taking profits in the long term brackets. For leveraged ETFs: some of the above applies for hedging, with lower capital. A ban isn't useful, limits maybe that are managed by brokers on individual basis, or some limits like a percentage of account size. Investors should have some access, and have some path towards expanding that access on merit. Thanks for your time.
Jason Brown Comment On Regulatory Notice 22-08
Comments: inverse ETFs: investors with small accounts and limited knowledge or no access to options have no way to hedge their position without inverse ETFs. Putting small retail at that kind of disadvantage exposes them to more risk and potential losses. It forces them into trying to time getting out of the market, and/or taking gains in the short term bracket instead of holding and hedging and taking profits in the long term brackets. For leveraged ETFs: some of the above applies for hedging, with lower capital. A ban isn't useful, limits maybe that are managed by brokers on individual basis, or some limits like a percentage of account size. Investors should have some access, and have some path towards expanding that access on merit. Thanks for your time.