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Shudong Huang Comment On Regulatory Notice 22-08

Shudong Huang
N/A

We should be able to choose the public investments that are right for us and our family. And public should be treated equal, public investment should be available to all of the public not just the privileged.

We should not go through any special process like passing a test before we can invest in public securities, like leveraged and inverse funds. I am using leveraged fund to gain exposure to the market while controlling my total exposure to the market, not to exceed my pre-set limit. I am using inverse fund to hedge my long positions. I am not using either or both for speculations.

Leveraged and inverse fund are important to my investment strategies. Please believe me if using it properly, leveraged fund can reduce my investment risk and preserve most of my capital. For example, Using 3 times leveraged fund to gain my exposure to the market ((using a little more than 1/3 of my capital, get 100% market exposure)) makes it possible for me to keep roughly 2/3 of my capital in cash . This cash position is very important for me to buy the dip. In worst case, if market crashes by 50%, I still have 2/3 of my initial capital in cash, and in that case, I would not only outperform the market, and more importantly, I can deploy the cash to buy the dip after market crashes without contributing more capital. I am using inverse fund to manage or hedge my investment risk. I do not use leverage fund and inverse fund for short term or long term speculation. Therefore leveraged fund and inversed fund both are very important for my investment strategies as a long term investors.

Any investment involves risk. Commodities, Options and futures, shorting positions may bear more risk for most retail investors than leveraged fund and inversed fund. At worst, leveraged fund will never lose more than 100% of its value. But commodities, option, future, and shorting positions may . Therefore, they are much less risky than commodities, options futures and shorting positions.