Comments: I would like to voice my opinion about leveraged & inverse products. I believe inverse products provide an inexpensive opportunity for individuals and advisors to hedge / short positions. Other options such as Puts are far more complex and expensive. As for leveraged ETF's, my simple thought is there is no need for these products whatsoever, with the key word being need. Can they work, sure, can they be incredibly dangerous, absolutely. Most people that trade or invest in these products have no idea how they work and how they can be hurt by them, they simply see the upside potential. Claiming the goal is to educate prior to purchase is nonsense, that's like saying people will read the policy agreement before they sign it. Even if there is a pop-up that says you can lose all of your money and you must click ok they will click and buy. I do not believe it is at all possible to educate people enough to warrant having these available. Put the client / investor first and ban these entirely. I believe I understand them but my ability to use them is far superseded by the many that have no idea and gamble with these toxic products.
Richard Grodin Comment On Regulatory Notice 22-08
Comments: I would like to voice my opinion about leveraged & inverse products. I believe inverse products provide an inexpensive opportunity for individuals and advisors to hedge / short positions. Other options such as Puts are far more complex and expensive. As for leveraged ETF's, my simple thought is there is no need for these products whatsoever, with the key word being need. Can they work, sure, can they be incredibly dangerous, absolutely. Most people that trade or invest in these products have no idea how they work and how they can be hurt by them, they simply see the upside potential. Claiming the goal is to educate prior to purchase is nonsense, that's like saying people will read the policy agreement before they sign it. Even if there is a pop-up that says you can lose all of your money and you must click ok they will click and buy. I do not believe it is at all possible to educate people enough to warrant having these available. Put the client / investor first and ban these entirely. I believe I understand them but my ability to use them is far superseded by the many that have no idea and gamble with these toxic products.