Dear FINRA:
As a systematic strategy, I have incorporated leveraged ETFs in my portfolio for the last six years. The strategy is mathematical and I follow an algorithm that determines when to buy or sell. I have use the strategy since 1989. It works and I am well-versed with the methods. I firmly believe that I should be able to choose the investment products that are key to my plan. Not a third-party regulator. These leveraged ETFs help me to protect my portfolio and enhance its returns. In my humble opinion, additional criteria to trade these leveraged ETFs by a third-party is not necessary or keeping with a level playing field for all investors. Thank you for your consideration.
Jon Dearborn Comment On Regulatory Notice 22-08
Dear FINRA:
As a systematic strategy, I have incorporated leveraged ETFs in my portfolio for the last six years. The strategy is mathematical and I follow an algorithm that determines when to buy or sell. I have use the strategy since 1989. It works and I am well-versed with the methods. I firmly believe that I should be able to choose the investment products that are key to my plan. Not a third-party regulator. These leveraged ETFs help me to protect my portfolio and enhance its returns. In my humble opinion, additional criteria to trade these leveraged ETFs by a third-party is not necessary or keeping with a level playing field for all investors. Thank you for your consideration.