Sirs: As an investment advisor with over 35 years experience, please accept this message as my opposition to regulation changes being considered regarding Inverse and Leveraged ETF's.
It is my belief that the advisor and/or the investing public should have the right to make investment choices for their accounts. Not the regulators.
As an experienced advisor, I believe I am capable of understanding leveraged and inverse funds and their risks therefore do not believe additional public securities tests are necessary.
In my business, both leveraged and inverse funds are an important part of my overall strategy (remember the markets go both up and down) and to enhance portfolio returns when suitable.
Mark Shafer Comment On Regulatory Notice 22-08
Sirs: As an investment advisor with over 35 years experience, please accept this message as my opposition to regulation changes being considered regarding Inverse and Leveraged ETF's.
It is my belief that the advisor and/or the investing public should have the right to make investment choices for their accounts. Not the regulators.
As an experienced advisor, I believe I am capable of understanding leveraged and inverse funds and their risks therefore do not believe additional public securities tests are necessary.
In my business, both leveraged and inverse funds are an important part of my overall strategy (remember the markets go both up and down) and to enhance portfolio returns when suitable.