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Jon Gasper Comment On Regulatory Notice 22-08

Jon Gasper
N/A

My first impression of this proposal is that it is a reaction to activities of individuals during the recent pandemic. Those who followed Wall Street Bets chasing meme stocks succumbed to, as Glenn Frey wrote in Smugglers Blues, "The lure of easy money is a very strong disease." As such the cure for such affliction would be better found with "Gamblers Anonymous" than regulation of financial instruments.
I have used both leveraged and inverse funds in conjunction with market timing strategies for the S&P 500 index funds. I have also used leverage funds in conjunction with commodities, which move in a very cyclical manner. My activities are based on an understanding of market cycles. The information on basic market cycles is readily available on the internet. Not to avail oneself to readily available information is a choice. Ignorance is a choice.
Now, my investments are not limited to these market activities. I also hold mutual funds invested in the S&P 500 along with various sector funds. The mutual fund investments were put in place decades ago when the time required to monitor investment was limited. The use of leveraged and inverse is not a put in place and walk away investment strategy. I can see the lure of such instruments during the recent pandemic. That was a very unique time. To impose regulation based on a unique event, I believe, is quite unwarranted.
The concept of limiting certain investment only to "accredited investors" is or should be well known. The idea of limiting the use of leveraged or inverse funds to those who you deem "accredited" I see as foolhardy. Anyone can go up and drop a quarter in a slot machine. As I said earlier "The lure of easy money is a very strong disease."