regarding the potential further restriction of leveraged ETFs : an investor does not him/herself borrow money to invest in a leveraged ETF, they simply buy it as they would any other security like a stock or bond. I personally invest in leveraged ETFs that track broad indices such as the S&P 500. Although these will be volatile, as they are levered, it is HIGHLY unlikely that they'd "go to zero" as the index would have to fall ~33% in a single trading day for that to happen to a 3x levered ETF. However, retail investors can invest in penny-stocks that can easily be wiped out completely and lose all their money, and are often more volatile than even a leveraged ETF which tracks an index. What is the rational for restricting what is essentially just a volatile investment product? I completely understand the effects of daily rebalancing and many would not want to own these products for the long-term. However, if one happens to be fortunate enough to own a leveraged ETF that tracks an index which has steady positive returns over many years, they can do very well. These risks of "volatility drag" are risks that investors need to be aware of but should not prohibit an investor from owning the security. Just as we investors are allowed to own individual stocks that can go to zero, we should be allowed to own levered funds whether it be for a short time or a long-term holding. Thank you.
Jason Farmer Comment On Regulatory Notice 22-08
regarding the potential further restriction of leveraged ETFs : an investor does not him/herself borrow money to invest in a leveraged ETF, they simply buy it as they would any other security like a stock or bond. I personally invest in leveraged ETFs that track broad indices such as the S&P 500. Although these will be volatile, as they are levered, it is HIGHLY unlikely that they'd "go to zero" as the index would have to fall ~33% in a single trading day for that to happen to a 3x levered ETF. However, retail investors can invest in penny-stocks that can easily be wiped out completely and lose all their money, and are often more volatile than even a leveraged ETF which tracks an index. What is the rational for restricting what is essentially just a volatile investment product? I completely understand the effects of daily rebalancing and many would not want to own these products for the long-term. However, if one happens to be fortunate enough to own a leveraged ETF that tracks an index which has steady positive returns over many years, they can do very well. These risks of "volatility drag" are risks that investors need to be aware of but should not prohibit an investor from owning the security. Just as we investors are allowed to own individual stocks that can go to zero, we should be allowed to own levered funds whether it be for a short time or a long-term holding. Thank you.