To Whom It May Concern: I am a self-directed individual investor writing to urge you in the strongest possible terms to avoid creating any new regulatory barriers to investing in leveraged or inverse funds. Your role in upholding basic investor protections is vital to the integrity of the market. While institutional investors can access a variety of financial instruments to take advantage of market volatility, individual investors have relatively few options other than inverse (or leveraged) exchange traded funds (ETFs). For example, some leveraged/inverse US Treasury ETFs (ex. TTT) have appreciated 50-60% YTD allowing individual investors to benefit from a macroeconomic trend that would otherwise be difficult to monetize. I am not aware of any data suggesting that these funds are riskier, more volatile, or have damaged individual investors more than poorly chosen individual stocks, which can be traded in an unrestricted manner. Modern individual investors have access to abundant educational material (some of which is provided by FINRA) and are especially incentivized to be good stewards of their own capital. Please refrain from imposing additional regulations on the trading of these funds, and thank you for your consideration.
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Jeff Bailey Comment On Regulatory Notice 22-08
To Whom It May Concern: I am a self-directed individual investor writing to urge you in the strongest possible terms to avoid creating any new regulatory barriers to investing in leveraged or inverse funds. Your role in upholding basic investor protections is vital to the integrity of the market. While institutional investors can access a variety of financial instruments to take advantage of market volatility, individual investors have relatively few options other than inverse (or leveraged) exchange traded funds (ETFs). For example, some leveraged/inverse US Treasury ETFs (ex. TTT) have appreciated 50-60% YTD allowing individual investors to benefit from a macroeconomic trend that would otherwise be difficult to monetize. I am not aware of any data suggesting that these funds are riskier, more volatile, or have damaged individual investors more than poorly chosen individual stocks, which can be traded in an unrestricted manner. Modern individual investors have access to abundant educational material (some of which is provided by FINRA) and are especially incentivized to be good stewards of their own capital. Please refrain from imposing additional regulations on the trading of these funds, and thank you for your consideration.