To Reader, As a retail investor that actively manages their own portfolio: - I use leveraged ETF's to hedge against and gain exposure to volatility in the markets as a way of running a long/short portfolio. - I understand that these products are not meant as long-term holding devices and are to be strategically applied depending on market conditions. - Limiting my ability to use these ETFs would restrict my abilities for hedging/leverage to just options which are a worse way for a retail trader to hedge/gain exposure compared to using these products. For example, if I'm trying to hedge against an impending drawdown in the tech sector I might consider using SQQQ shares instead of QQQ put spreads. - Most regular retail don't even know what many of these products are, outside of SOXL, TQQQ, and SQQQ. - The requirement to demonstrate a high net worth to use one of these products is essentially gatekeeping for retail investors. It's one thing to gatekeep based on knowledge, but another thing entirely to impose a rule based on net worth.
Peter Pham Comment On Regulatory Notice 22-08
To Reader, As a retail investor that actively manages their own portfolio: - I use leveraged ETF's to hedge against and gain exposure to volatility in the markets as a way of running a long/short portfolio. - I understand that these products are not meant as long-term holding devices and are to be strategically applied depending on market conditions. - Limiting my ability to use these ETFs would restrict my abilities for hedging/leverage to just options which are a worse way for a retail trader to hedge/gain exposure compared to using these products. For example, if I'm trying to hedge against an impending drawdown in the tech sector I might consider using SQQQ shares instead of QQQ put spreads. - Most regular retail don't even know what many of these products are, outside of SOXL, TQQQ, and SQQQ. - The requirement to demonstrate a high net worth to use one of these products is essentially gatekeeping for retail investors. It's one thing to gatekeep based on knowledge, but another thing entirely to impose a rule based on net worth.