ProShares offer a choice to investors. Disclosure of risks associated with ProShare's ETFs are well documented. Communication is regularly provided and easily reviewed by the public at large. Introducing illiquidity to the marketplace does not benefit existing shareholders and rather hurt small investors like myself. I currently invest in leveraged funds to take advantage of short to medium horizon opportunities when market stresses occur. I do not want to take margin debt when such opportunities occur. Margin debt may completely wipe out my equity position if acute market stresses (e.g. COVID pandemic route) is called. In my opinion, investors' easy access to margin debt offered by brokerages or trading houses is far more harmful to small investors given that margin debt limits are largely dependent on the loan to value ratios for each type of security purchased. There should be no reason why FINRA should place additional restrictions on leveraged products when ProShares already clearly and extensively communicates risks associated with such investments.
Maxwell Ma Comment On Regulatory Notice 22-08
ProShares offer a choice to investors. Disclosure of risks associated with ProShare's ETFs are well documented. Communication is regularly provided and easily reviewed by the public at large. Introducing illiquidity to the marketplace does not benefit existing shareholders and rather hurt small investors like myself. I currently invest in leveraged funds to take advantage of short to medium horizon opportunities when market stresses occur. I do not want to take margin debt when such opportunities occur. Margin debt may completely wipe out my equity position if acute market stresses (e.g. COVID pandemic route) is called. In my opinion, investors' easy access to margin debt offered by brokerages or trading houses is far more harmful to small investors given that margin debt limits are largely dependent on the loan to value ratios for each type of security purchased. There should be no reason why FINRA should place additional restrictions on leveraged products when ProShares already clearly and extensively communicates risks associated with such investments.