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Samuel Scott Comment On Regulatory Notice 22-08

Samuel Scott
N/A

Occasionally, I have used "complex investment products," such as leveraged or inverse funds in my portfolio for specific purposes. As a retired person, I need growth in my investments to fund my living expenses and so far, 2022 has not been very kind. One bright spot in my portfolio has been the ProShares ETF that shorts the 20-year treasury bond which produces a return in a rising interest rate environment.

Specific funds that fit special situations should be available to the investing public. Otherwise, only very affluent investors with expensive advisors will be able to tap into
opportunities such as I described above.

Leveraged and inverse funds do carry extra risk and are often more volatile than ordinary funds and investors need to realize that and invest accordingly. That said, investors
who consider these products generally have the intelligence to understand their workings and the associated objectives and risks involved. Thus, I would ask that leveraged and inverted funds continue to be made available to the investing public on the same basis as they are today without added regulation or paperwork.