Limited use of leveraged and leveraged inverse ETFs serve an important part of our family's investment portfolio; the risks associated with these products -- the impact of volatility on returns, tracking errors associated with holding leveraged ETPs longer than 1 day, etc. are *very* clearly spelled out in each ETP's prospectus, with most going so far as to provide tables to illustrate such risks.
Given the caution already urged by brokers and the clarity and concision with which ETP providers communicate risks to potential investors, there's no reasonable need to require tests, net worth requirements or any other restrictions; this is particularly true when one compares the risk of such investment instruments with the idiosyncratic risks associated with holding stocks, sector ETFs and other common investments.
Simply put, there's no problem that requires solving in this instance and by adding additional restrictions to these products, FINRA will undermine the free market with potentially disastrous consequences (reductions in trading volume resulting in liquidity issues, pricing issues; brokers dropping these products entirely because they don't want to incur the costs associated with supporting restrictions imposed by FINRA) for common retail investors like my husband and I.
Rather than complex products themselves, *it's additional restrictions floated by FINRA in the 22-08 notice that are putting our family's financial security at risk*.
Sarah Costa Comment On Regulatory Notice 22-08
Limited use of leveraged and leveraged inverse ETFs serve an important part of our family's investment portfolio; the risks associated with these products -- the impact of volatility on returns, tracking errors associated with holding leveraged ETPs longer than 1 day, etc. are *very* clearly spelled out in each ETP's prospectus, with most going so far as to provide tables to illustrate such risks.
Given the caution already urged by brokers and the clarity and concision with which ETP providers communicate risks to potential investors, there's no reasonable need to require tests, net worth requirements or any other restrictions; this is particularly true when one compares the risk of such investment instruments with the idiosyncratic risks associated with holding stocks, sector ETFs and other common investments.
Simply put, there's no problem that requires solving in this instance and by adding additional restrictions to these products, FINRA will undermine the free market with potentially disastrous consequences (reductions in trading volume resulting in liquidity issues, pricing issues; brokers dropping these products entirely because they don't want to incur the costs associated with supporting restrictions imposed by FINRA) for common retail investors like my husband and I.
Rather than complex products themselves, *it's additional restrictions floated by FINRA in the 22-08 notice that are putting our family's financial security at risk*.