Comments: As a retired Registered Investment Advisor of 38 years without a single complaint, I highly recommend you NOT change investor's access or ability to trade complex products, including and especially leveraged and inverse ETFs. Retail investor's net purchases of such leveraged ETFs have been rising steadily over the past few years, with the 10-day rolling sum recently exceeding $1b, demonstrating their demand. When you exclude such investors you leave the only true leveraged opportunities to larger institutions who can trade with derivatives, far too complex and with much higher minimum investment. With leveraged ETFs the playing field is fairer, allowing the "little guy" the ability to trade on a leveraged scale than would otherwise be unavailable. I realize that FINRA is trying to protect the integrity of the markets and project a since of fairness, but it is not their job to protect investors for being able to take risks and enjoy the rewards. This diminishes free enterprise for the masses to the benefit of the larger entities and individuals.
John Schannep Comment On Regulatory Notice 22-08
Comments: As a retired Registered Investment Advisor of 38 years without a single complaint, I highly recommend you NOT change investor's access or ability to trade complex products, including and especially leveraged and inverse ETFs. Retail investor's net purchases of such leveraged ETFs have been rising steadily over the past few years, with the 10-day rolling sum recently exceeding $1b, demonstrating their demand. When you exclude such investors you leave the only true leveraged opportunities to larger institutions who can trade with derivatives, far too complex and with much higher minimum investment. With leveraged ETFs the playing field is fairer, allowing the "little guy" the ability to trade on a leveraged scale than would otherwise be unavailable. I realize that FINRA is trying to protect the integrity of the markets and project a since of fairness, but it is not their job to protect investors for being able to take risks and enjoy the rewards. This diminishes free enterprise for the masses to the benefit of the larger entities and individuals.