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Shawn Asamoto-Brown Comment On Regulatory Notice 22-08

Shawn Asamoto-Brown
N/A

Dear Finra,

Leveraged funds are an important part of my investment strategy. Please do not make them difficult to access.

Yes, I understand and think most understand that the daily reset on leveraged funds means that an investor won't automatically earn the multiple of the index.

That said, they are tax efficient relative to futures for those of us who must invest in taxable brokerage accounts.

I do trade equity futures and am comfortable doing so, but leveraged funds are an important tool for me.

As regulators, I guess protecting investors is your goal but honestly why don't you focus more on the deregulated crypto markets where who knows what is going on.

Assets are said to be productive (and pay interest) yet they really have no basis to being do so as they are only able to do so when someone will pay to interest to leverage them. Yet the collateral on these items is other crypto currencies and it is really difficult to determine what will happen in a run and crash.

Let's be honest. Triple leveraged ETFs are not a risk to markets the way crypto, options or futures are.

Also, having been an expat for many years, I can personally attest how difficult it is to get access to brokerage services when overseas. Requiring brokers to jump though hoops to allow trading of leveraged funds only means one things. Those brokers who do allow American's overseas to trade ETFs will simply not offer leveraged products. This is as their departments which cater to (and do compliance on) expats are limited compared to the main brokerage and will not have the budget for additional compliance.

Leverage funds are not a risk to my retirement. A system crash from failure to regulate cryptos is. Also, anyone can watch a YouTube video on options and learn "how to make millions with options". The suckers and get rick quick dreamers are going there.

Finally, many invest when the carry a mortgage. That is a form of leverage too. If you are so against leverage and think people can't use it responsibly, why don't you require training for anyone with a mortgage who is buying stocks. After all, a downturn and job loss can leave you exposed with a mortgage to pay. Isn't it an investor's job to determine how much leverage is appropriate for them?

I don't carry a mortgage and use leveraged ETFs instead. Am I taking more risk that someone with a supersize interest only loan and equities purchased instead of paying their loan off.

I don't believe you are realistically able to make such a determination. Please allow me the freedom to make that determination for myself.