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Russ Ferreri Comment On Regulatory Notice 22-08

Russ Ferreri
N/A

It does not serve public interest nor protect investors to restrict inverse or leveraged ETFs. The cost and tax efficiency of these vehicles are some of the only ways the public can implement constructive hedging instruments akin to institutions. Even better: they are important liquidity providers and trade in the open marketplace vs. bilateral prime brokerage arrangements that unwind in a collateral way (i.e. Archegos). Taking this away would be a step backwards. Stop protecting the monopoly of primary broker-dealers. Last I checked, their unprecedented levels of excess reserves were funded by the public via Fed purchases.