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Nicholas Magda Comment On Regulatory Notice 22-08

Nicholas Magda
N/A

Leveraged Index Funds are less complex than the mutual funds non-accredited investors can purchase through personal brokerage funds. This is largely for 3 reasons: The fees are easier to understand, distributions and dividends are easier to understand, and returns are easier to understand.

Mutual funds are notorious for complicating their fee structures and, (as someone who has passed the SIE exam) frankly they require the knowledge of someone in the securities industry to properly understand. Several filters are required to figure out what your net fee will actually be, and often you have to pay the fee of a financial advisor to truly understand. Leveraged index funds have lower fees and rarely require a cash fee to the investor at the time of purchase or exit. Investors need not consult a financial advisor to know that their return is decreased by the single management fee clearly listed when the log in to their brokerage account.

Almost everyone, whether an investor or not, has heard of distributions and dividends. However, mutual funds have taken this basic concept, complicated it, and obscured it. Distribution of mutual fund assets often appear to be dividends and greatly complicate the tax consequences for uneducated investors. Leveraged index funds often do not pay a dividend and almost never pay a distribution. Investors can quickly look at the dividend rate and immediately understand it with the help of a single Investopedia page.

Finally, returns are easier to understand in leveraged index funds. Leverage index funds clearly state what return they target and what it translates to. Understanding that SPXL targets a 3x return of whatever the S&P500 returns is much simpler than than trying to discern what return a mutual fund will give you. Investors are often already familiar with the indices and markets that leveraged funds track, the leverage simply gives them a straightforward and easy to understand way to add their desired level of risk to their portfolio.

Overall, if accredited investor status is required to purchase leveraged funds on the basis that they are "complex products", then mutual funds, and many other investment products, should require the same level of control.