I'm 10-15 years from retirement as a senior business systems analyst for over 25 years, with an M.B.A. and B.S. Psychology (thus, understand stats, metrics, patterns, cause & effect), who's spent the past 5 years studying financial markets and investing research, primarily so that I can retire sooner or better, but also to better understand economics, markets and business. Please don't interfere with my ability to trade leveraged ETFs. I own leveraged ETFs in certain sectors of U.S., including sectors that outperform, broad market indexes for capital efficient market exposure, geographic foreign markets to avoid excess dependence on domestic markets, and occasionally, commodity ETNs for oil and gold when they make sense, like right now. I understand that these are trading vehicles and not appropriate for long buy & hold strategies. I have numerous sophisticated, reliable research inputs, as well as stop loss strategies, to help me know when to buy and sell them, and at what limit price triggers. One thing many don't consider when discrediting leveraged ETFs. First of all, inverse leveraged ETFs are a godsend hedge for market volatility for those who either cannot or do not wish to trade options and other derivatives. Second, avoiding time decay and strike price, in- and out-of-the-money complexities of derivatives are an advantage to any leveraged fund, not just an inverse. Third, and very important to me--since I do trade options as well, though not nearly as much because of their volatility and risk--is leveraged funds allow me to gain as much as with a broader basket of holdings in a single security, so avoiding single stock risk, while still enjoying the general trend of the best performers in that ETF. Meaning, for example, if someone who want exposure to a sector that will do well over intermediate term, such as energy sector or cybersecurity or Brazil, India or Canada, but doesn't want to risk putting much funds into single stocks from those promising sectors, leveraged ETFs are a prudent option, so long as you understand how they work and that they require more attention and research as a trading instrument than our core investments necessitate. I'm all for transparency and requiring additional disclosures where warranted, but preventing me using these securities in my IRA and other broker accounts is going too far, would really disappoint and discourage me about the ability of our government to protect its citizens through education, information and rehabilitation, instead of through prohibitions that infringe on freedom of choice and reducing means to outperform the market, so that we can build wealth sooner and protect ourselves with more effective hedges during periods of greater risk and volatility. Please carefully consider my concerns and wishes, as I respect your due diligence in weighing public feedback on related issues. I can honestly say I wrote these thoughts myself without the aid of any script, based on my education, investing experience and work experience, and if I can articulate this to anyone, then I hope you agree I know what I'm talking about, and can manage my financial affairs just fine. Thank you.
Tim Gilbert Comment On Regulatory Notice 22-08
I'm 10-15 years from retirement as a senior business systems analyst for over 25 years, with an M.B.A. and B.S. Psychology (thus, understand stats, metrics, patterns, cause & effect), who's spent the past 5 years studying financial markets and investing research, primarily so that I can retire sooner or better, but also to better understand economics, markets and business. Please don't interfere with my ability to trade leveraged ETFs. I own leveraged ETFs in certain sectors of U.S., including sectors that outperform, broad market indexes for capital efficient market exposure, geographic foreign markets to avoid excess dependence on domestic markets, and occasionally, commodity ETNs for oil and gold when they make sense, like right now. I understand that these are trading vehicles and not appropriate for long buy & hold strategies. I have numerous sophisticated, reliable research inputs, as well as stop loss strategies, to help me know when to buy and sell them, and at what limit price triggers. One thing many don't consider when discrediting leveraged ETFs. First of all, inverse leveraged ETFs are a godsend hedge for market volatility for those who either cannot or do not wish to trade options and other derivatives. Second, avoiding time decay and strike price, in- and out-of-the-money complexities of derivatives are an advantage to any leveraged fund, not just an inverse. Third, and very important to me--since I do trade options as well, though not nearly as much because of their volatility and risk--is leveraged funds allow me to gain as much as with a broader basket of holdings in a single security, so avoiding single stock risk, while still enjoying the general trend of the best performers in that ETF. Meaning, for example, if someone who want exposure to a sector that will do well over intermediate term, such as energy sector or cybersecurity or Brazil, India or Canada, but doesn't want to risk putting much funds into single stocks from those promising sectors, leveraged ETFs are a prudent option, so long as you understand how they work and that they require more attention and research as a trading instrument than our core investments necessitate. I'm all for transparency and requiring additional disclosures where warranted, but preventing me using these securities in my IRA and other broker accounts is going too far, would really disappoint and discourage me about the ability of our government to protect its citizens through education, information and rehabilitation, instead of through prohibitions that infringe on freedom of choice and reducing means to outperform the market, so that we can build wealth sooner and protect ourselves with more effective hedges during periods of greater risk and volatility. Please carefully consider my concerns and wishes, as I respect your due diligence in weighing public feedback on related issues. I can honestly say I wrote these thoughts myself without the aid of any script, based on my education, investing experience and work experience, and if I can articulate this to anyone, then I hope you agree I know what I'm talking about, and can manage my financial affairs just fine. Thank you.