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Roy Netherton Comment On Regulatory Notice 22-08

Roy Netherton
N/A

Comments: The leveraged and inverse ETF products offered by Direxion and certain other institutions include complete descriptions of the risks associated with these types of investments and frequent warnings regarding risk in the product descriptions. Direxion even offers comprehensive explanations and educational materials with detailed product information. It is very clear in the fund descriptions that these types of funds are NOT to be considered long term investments and should be managed daily.
These types of products offer retail investors the opportunity to participate in critical risk management strategies which would otherwise only be available to institutions and extremely high net worth individuals. Limiting access to such products is not in the best interest of the majority of individual investors.