RE: comments about Reg. Notice 22-08 Many of my friends prefer using financial professionals, I prefer self-directed platforms. As an individual on a self-directed platform, I've become much more aware and capable of managing the risks for products like leveraged ETFs. My 20+ year experience with these instruments is positive and they do what they advertise. Their beauty is in their simplicity, a 2x or 3x move on an underlying index is quite easy to understand and make corresponding risk calculations. Attaining favorable investment outcomes using leveraged ETFs is not a matter of having a proper understanding of them, it is a matter of properly understanding the valuation of the underlying market index. It’s not all that necessary to understand underlying leveraged ETF structures. It’s quite simple, they move 2x or 3x to whatever underlying index they’re structure around. And any trader/investor in these, quickly comes to understand what that means. So it’s really sort of irrelevant, an understanding of the financial complexity of leveraged ETFs so long as they work as advertised and which in my experience has been the case. I am not familiar with Defined outcome exchange-traded funds, Interval or Tender-offer funds. Options are difficult to manage since they have more time value decay than leveraged ETFs. So there may be types of ETFs suitable only for the professional application, but the lowly leveraged ETF that directly tracks an index 2x or 3x is really quite simple to understand and manage with just limited experience. It’s beyond my understanding to address the potential of complex products to create system wide risks. Find a way if you do add regulation, to not shut out small investors from products like leveraged ETFs. Maybe there are ways to reduce overall system volume while maintaining broad opportunities for all? Perhaps a nominal fee structure which could generate government revenue and also limited volumes?
Ken Kauffman Comment On Regulatory Notice 22-08
RE: comments about Reg. Notice 22-08 Many of my friends prefer using financial professionals, I prefer self-directed platforms. As an individual on a self-directed platform, I've become much more aware and capable of managing the risks for products like leveraged ETFs. My 20+ year experience with these instruments is positive and they do what they advertise. Their beauty is in their simplicity, a 2x or 3x move on an underlying index is quite easy to understand and make corresponding risk calculations. Attaining favorable investment outcomes using leveraged ETFs is not a matter of having a proper understanding of them, it is a matter of properly understanding the valuation of the underlying market index. It’s not all that necessary to understand underlying leveraged ETF structures. It’s quite simple, they move 2x or 3x to whatever underlying index they’re structure around. And any trader/investor in these, quickly comes to understand what that means. So it’s really sort of irrelevant, an understanding of the financial complexity of leveraged ETFs so long as they work as advertised and which in my experience has been the case. I am not familiar with Defined outcome exchange-traded funds, Interval or Tender-offer funds. Options are difficult to manage since they have more time value decay than leveraged ETFs. So there may be types of ETFs suitable only for the professional application, but the lowly leveraged ETF that directly tracks an index 2x or 3x is really quite simple to understand and manage with just limited experience. It’s beyond my understanding to address the potential of complex products to create system wide risks. Find a way if you do add regulation, to not shut out small investors from products like leveraged ETFs. Maybe there are ways to reduce overall system volume while maintaining broad opportunities for all? Perhaps a nominal fee structure which could generate government revenue and also limited volumes?