This is really not going to help individual retail investors. Lots of retail investors would be losing valuable hedging and speculating tools in terms of leveraged and inverse ETF's. Many of these investors may utilize cash accounts and have no other way to go short in the market without buying put options, which is another layer of approval. As such, ETF's are the most accessible and easy to trade and least complex of hedging instruments and to put these kind of access restrictions is mind-boggling. A test or attestation and reading and understanding specifications and readings on the instruments is fair. But high net worth and cooling off periods? That is beyond the pale. Retail investors do not need restrictions as a punishment for those that do not carry out their due diligence. This is unfair, shortsighted, and shows legislative lack-of-understanding of the investment space. This affects us all and will only serve to intensify wealth gaps. Please do not do this.
Todd Miller Comment On Regulatory Notice 22-08
This is really not going to help individual retail investors. Lots of retail investors would be losing valuable hedging and speculating tools in terms of leveraged and inverse ETF's. Many of these investors may utilize cash accounts and have no other way to go short in the market without buying put options, which is another layer of approval. As such, ETF's are the most accessible and easy to trade and least complex of hedging instruments and to put these kind of access restrictions is mind-boggling. A test or attestation and reading and understanding specifications and readings on the instruments is fair. But high net worth and cooling off periods? That is beyond the pale. Retail investors do not need restrictions as a punishment for those that do not carry out their due diligence. This is unfair, shortsighted, and shows legislative lack-of-understanding of the investment space. This affects us all and will only serve to intensify wealth gaps. Please do not do this.