Skip to main content

Ryan Montgomery Comment On Regulatory Notice 22-08

Ryan Montgomery
N/A

I strongly oppose restricting access to any public investments to those who already have significant financial and/or social capital. This is the sort of self-dealing that gives the financial industry the reputation of rigging the game in its own favor at the expense of retail investors. I personally use 3X leveraged funds to potentially enhance returns on a small portion of my overall portfolio. I understand the risks, and I'm currently experiencing the significant downside and volatility without losing sleep. I purchased these leveraged products on the assumption that I could rebalance among asset classes and between various duration risks, and freezing me out of further trading could force liquidation while I'm down, or force me to take on more risk than I originally intended, without the ability for me to make up for losses with a 3X leveraged run to the upside. I can also easily envision any "cooling off" period interfering with the timing of my rebalances. These products also give young investors the ability to take a lifecycle investing approach to their portfolios, potentially giving them a head start on financial security, and allowing them to de-risk as they age. I wish I had that opportunity when I was younger. As long as these investment products are available to the public in any form, people should have the freedom to make these choices based on their own assessment of risk versus reward. Changing the rules mid-stream would be deeply unfair in particular to those who are relying on rebalancing to compensate for the volatility risk of leveraged products. Please leave these "complex" products alone, and allow investors to do their own due diligence via the prospectuses as intended.