To the SEC:
Please do NOT adopt the proposed rule!
I have included leveraged and inverse leveraged funds in my portfolio for well over a decade. I understand the concept of volatility drag and as an antidote, I employ modified dollar-cost averaging to lower my cost basis.
It seems criminally unfair for one branch of the government the Fed to create an overinflated market, only to have another branch of the government the SEC barge in and take away the one tool we had to defensively hedge against the former.
Yes I am hedged against a major fall in the stock market. When that happens which every pro know it will eventually my holdings will rise inversely and my hedge will have succeeded. If you take away my ability to buy and sell those leveraged funds you will have slaughtered me.
Most investors wager that the market will always go up. But we know that irrational exuberance will produce an unsustainable bubble so there are also investors like me who invest with the knowledge that markets do not always go up and that greed can easily and quickly give way to fear.
It will be grossly unfair for the government at this late date in the market cycle to put its thumb on the scale in favor of only bulls. It is unreasonable and un-historical.
Please do not.
Stuart Rickey Comment On Regulatory Notice 22-08
To the SEC:
Please do NOT adopt the proposed rule!
I have included leveraged and inverse leveraged funds in my portfolio for well over a decade. I understand the concept of volatility drag and as an antidote, I employ modified dollar-cost averaging to lower my cost basis.
It seems criminally unfair for one branch of the government the Fed to create an overinflated market, only to have another branch of the government the SEC barge in and take away the one tool we had to defensively hedge against the former.
Yes I am hedged against a major fall in the stock market. When that happens which every pro know it will eventually my holdings will rise inversely and my hedge will have succeeded. If you take away my ability to buy and sell those leveraged funds you will have slaughtered me.
Most investors wager that the market will always go up. But we know that irrational exuberance will produce an unsustainable bubble so there are also investors like me who invest with the knowledge that markets do not always go up and that greed can easily and quickly give way to fear.
It will be grossly unfair for the government at this late date in the market cycle to put its thumb on the scale in favor of only bulls. It is unreasonable and un-historical.
Please do not.