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Michael Milburn Comment On Regulatory Notice 22-08

Michael Milburn
N/A

Hi, I'm writing with concern that my ability to hedge my portfolio volatility via inverse ETFs is under consideration of being limited or taken away. My only comment is that the ability to hedge downside risk via inverse ETF is one of the few ways other than outright selling to cash that I have to reduce risk in certain environments. In a rising rate environment in particular bonds are unhelpful in this regard, so inverse ETFs provide a direct way to reduce downside risk. Please be careful with any regulation you put on my ability to protect my downside when conditions warrant.