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Philip Howard Comment On Regulatory Notice 22-08

Philip Howard
N/A

If FINRA limits access to levered ETFs, they are only hurting the retail investors. Levered ETFs allow investors the ability to achieve better long-run performance for their retirement portfolios. On average, the market return is about 10% since WW2. Levered ETFs allow investors the ability to easily lever these positive expected returns and grow their portfolio without the risk of margin requirements found elsewhere like futures. Obviously there is risk in investing, and the market may decline in some years. Investors should be allowed to decide if they want to have this risk exposure. No one is forcing investors into levered positions. FINRA should not prevent investors from having the option to responsibly invest in levered positions. In essence, you're exacerbating wealth inequality. Retail investors would not get to participate in positive expected market returns, while institutional investors still have other means to easily achieve leverage and grow their wealth. Why would you make a regulation that harms retail investors?