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Theodore Horner Comment On Regulatory Notice 22-08

Theodore Horner
N/A

Comments: I am a small, (60K portfolio) non-commercial investor, approaching retirement, and I believe FINRA's attempts to require enhancements to current rules on Leveraged and Inverse ETFs (L&I Funds) unnecessarily limits investor choice. Such ETFs are an essential part of my portfolio. FINRA adoption of a more restrictive stance on non-commercial investors ability to buy these ETFs would damage my ability to secure adequate funds for my retirement. I am well aware of the risks of such ETFs. I am aware that they are not for long term investment and must be actively managed on a daily basis. My broker already disallows trading on margin for these products. My broker also disallows pattern trading, (aka "Day Trading"), which L&I Funds are often used for, in accounts with a portfolio value less than $5000. My broker also warns account holders about potential pattern trading violations. In my opinion, my broker's rules and warnings are sufficient to control L&I Funds activity. Government restrictions on top of broker rules would be counterproductive for small and mid-range investors, because they would damage their ability to reach reasonable investment goals.