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Mitchel Krause Comment On Regulatory Notice 22-08

Mitchel Krause
N/A

I'm a 26 year industry veteran with over a decade on the retail side, over a decade on the institutional side w/corp fin, syndicate, corporate buyback experience - we literally wrote the 10b-5-1 plans with out attorneys back before they became popular.

I literally left the confines of traditional Wall Street for their inability to manage risk and the handcuffs they strap on advisors in not allowing them to manage risk properly. Outside of short positions, there are few asset classes which have posted positive returns to date.

$DXY (the US Dollar)
$GLD (Gold up nearly 6%)
$XLE

Every other sector within the SPY is getting smoked as I write to you...

Bonds have gotten smoked - worst S&P performance to begin the year since the 1930's worst nasdaq start on record.

Not for those of us who use inverse ETFs to preserve clients wealth responsibly. These are strategic tools that are paramount to long only IRA's and retirement accounts trying to preserve wealth and hedge risk during troubling times and DON'T have the ability to outright short individual names. Taking this tool away is the OPPOSITE of prudent risk management.

Will some use these tools poorly ... possibly - but if someone is unhappy with performance, they can find a new manager as not all are created equally...

We humbly submit taking away inverse ETFs is removing an imperative risk management tool of a prudent investor at a time when they need it the most -