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Jeffrey Bolden Comment On Regulatory Notice 22-08

Jeffrey Bolden
N/A

Comments: Back in the 1990s when I started it was quite common for people who wanted to trade leveraged diversified products to establish a mutual fund account at Rydex (now part of Guggenheim). There were other products which were similar at the time though I think most have closed. The most popular trading were the Fidelity Select funds which had a 3% load specifically to allow for more rapid trading of various types. These products don't not seem much different to me than the ETF broker based systems of today.

Using these platforms there was no need to prove a high net worth. While I suspect I easily qualify for whatever the criteria might be I don't see any reason to create this sort of artificial control on leveraged products. I'll explain why.

I've seen no shortage of stupidity in my 28 years talking to investors just starting out. Today is no exception: NFTs make the 1990s internet stocks look comparatively sane. But in all those years, and the countless idiocy I've encountered, not once have I seen a person in a leveraged product not understand they were in a leveraged product or what leverage means. Similarly with inverse products. People who get in accidentally get told to buy VOO or similar ETFs. No one recommends leveraged or inverse products who is not presenting them as vehicles for trading.

I'd also comment that I have seen lots of investors who are terrified of naked leverage (i.e. won't use actual margin, shorts, futures...) comfortably using these products as part of a portfolio allocation. For example various long leveraged VIX/Inverse VIX combos against an SP500 ETF to control portfolio volatility.

I like the idea of the exam. I don't mind a minimum like $25k, similar to day trader rules or something to keep kids out. But these products should not be put on par with accredited investor products.