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Ronald Brown Comment On Regulatory Notice 22-08

Ronald Brown
N/A

I have come to learn that the FINRA is considering measures to curb investment availability of inverse and leveraged Exchange Traded Funds. I strongly object to any measures that could restrict my choice of using these ETF's.

I don't normally invest in these types of ETF's. I only use inverse ETF's during market down turns, like we are having now, to hedge my portfolio. I used them in previous market down turns in 1987 and 2008 to allow me maintain positions that wanted to hold long term and they did just what I wanted them to do.

I am not an options trader. And do not wish to be one so using options to hedge my portfolio is not an option for me. I much prefer using an ETF.

It is my understanding that it is be considered that only high net worth individual should be allowed to invest in these investment vehicles. The deep pocket investors and investment firms already have advantages over a small investor like me. Pushing me out of the game only makes the fat cats fatter and punishes the likes of me.

Also, I have learned that cooling off periods where you cant invest is being considered. I recall the push back in 2008 when investors like me were buying inverse ETF's and the fat cat Wall Street crowd was crying foul because of it. They have so many advantages over the small investor as it is. Let us have the ability to hedge our investments.

Leveraged and Inverse ETF's have their pitfalls and their math can be confusing. You have to understand how they can work against your goals. They should only be held short-term.

I don't object to a detailed explanation of how holding these investments act over time placed in the prospectus. But please don't restrict their availability.

Thank you for time.