Stephen Schuller Comment On Regulatory Notice 22-08

Any proposal to limit an investors ability to purchase inverse funds would not be well received and obviously ill-timed given market conditions. Every investment contains risk and a regulatory authority should not posses the authority to restrict an investors ability to use products such as these that can actually mitigate risk in one's overall portfolio. If such rules are implemented, where does regulation stop? Will you restrict purchases of stocks with no earnings, junk bond funds, short sales, options? Concentrate on education and risk disclosure documents for investors that are concise and allow investors to make decisions for their own portfolio. Otherwise, one's only option to protect themselves from market decline is to liquidate long positions which can carry a tax and cost burden. It also places additional stress on the investor as it makes them become market timers as opposed to simply keeping their long positions and adding a few hedges should they wish to do so in times of heightened market volatility.