Please allow unrestricted availability of leveraged in inverse ETF's. Many private individuals are choosing to manage their own retirement and investment funds. These instruments provide hedging and seasonal positioning according to market conditions. We simply believe that a hired professional would not put as much attention into the changing market environment as we do. Furthermore, even if the hired professional wanted to, his financial choices are restricted to the approved fiduciary set of narrow options. (wide diversification, preset bond/equity proportions, low turnover, etc.) These professional restrictions do not allow them the opportunity to be rapidly responsive to daily changes in market conditions. Active investors need these instruments to both hedge, and use leverage according to market conditions.
Ryan McKinnon Comment On Regulatory Notice 22-08
Please allow unrestricted availability of leveraged in inverse ETF's. Many private individuals are choosing to manage their own retirement and investment funds. These instruments provide hedging and seasonal positioning according to market conditions. We simply believe that a hired professional would not put as much attention into the changing market environment as we do. Furthermore, even if the hired professional wanted to, his financial choices are restricted to the approved fiduciary set of narrow options. (wide diversification, preset bond/equity proportions, low turnover, etc.) These professional restrictions do not allow them the opportunity to be rapidly responsive to daily changes in market conditions. Active investors need these instruments to both hedge, and use leverage according to market conditions.