Steven Rosenfeld Comment On Regulatory Notice 22-08
Steven Rosenfeld
N/A
In the past 20 or so years, we have had three major market corrections of approximately 37%, 40% and 50%. In all of those cases, it would take close to 10 years to recover the losses, based on normal rates of returns (for example, a 50% drop requires 100% returns to become whole). If you started retirement savings at a time later than ideal, for any number of reasons, you need the ability to try to retire at acceptable levels, and leveraged funds can allow this to take place. Leveraged funds greatly reduced, in my own case, the time for catch-up trades in those circumstances, and allowed the recovery of the major losses of big corrections.
I need the freedom to make my own investment choices. In addition, I am required to attest to my brokerage that I am aware of the risks, The leveraged funds allow me to diversify my portfolio by spreading risk with lower cash positions. I can get a wider array of diverse, leveraged funds to take positions as protection for losses.
Finally, there is inherent risk in markets. If you study the volatility of an asset class such as bitcoin vs. leveraged funds, you will find that many of the funds are far less volatile, yet bitcoin is see as a valid and allowable investment. The same can hold true for other "legal" investment vehicles of options or margin trading, yet those are allowable investment instruments.
It is to this investor an ill-advised decision to impinge on investor freedom, disallow catch-up trades for large market corrections, reduce the option of smaller cash outlays by using leveraged funds for diversification, and to unfairly allow other investment vehicles with greater risk potential to exist while disallowing leveraged funds.
Steven Rosenfeld Comment On Regulatory Notice 22-08
In the past 20 or so years, we have had three major market corrections of approximately 37%, 40% and 50%. In all of those cases, it would take close to 10 years to recover the losses, based on normal rates of returns (for example, a 50% drop requires 100% returns to become whole). If you started retirement savings at a time later than ideal, for any number of reasons, you need the ability to try to retire at acceptable levels, and leveraged funds can allow this to take place. Leveraged funds greatly reduced, in my own case, the time for catch-up trades in those circumstances, and allowed the recovery of the major losses of big corrections.
I need the freedom to make my own investment choices. In addition, I am required to attest to my brokerage that I am aware of the risks, The leveraged funds allow me to diversify my portfolio by spreading risk with lower cash positions. I can get a wider array of diverse, leveraged funds to take positions as protection for losses.
Finally, there is inherent risk in markets. If you study the volatility of an asset class such as bitcoin vs. leveraged funds, you will find that many of the funds are far less volatile, yet bitcoin is see as a valid and allowable investment. The same can hold true for other "legal" investment vehicles of options or margin trading, yet those are allowable investment instruments.
It is to this investor an ill-advised decision to impinge on investor freedom, disallow catch-up trades for large market corrections, reduce the option of smaller cash outlays by using leveraged funds for diversification, and to unfairly allow other investment vehicles with greater risk potential to exist while disallowing leveraged funds.