Dear SEC, I'm vehemently opposed to Rule #S7-24-15, as it limits the available securities to the public which are within their right to own. As a licensed investment advisor, we already provide the expertise to our clients to explain leveraged and inverse funds as investments. Specifically, these are not recommended for every client, but can be quite useful for clients as a hedge, and should be available to the investor without a steep set of criteria that limits the market breadth and increases risk by reducing real market forces. Leveraged funds also enable the right investor to find more gains in otherwise flat returns, as long as prudently invested, representing no more than 1-2% of a portfolio. Research completed by knowledgable participants like Investment Advisors currently meets the criteria outlined in the proposed legislation, so it appears it is unnecessary, and potentially harmful by limiting the number of investors and consolidating markets which can distort valuation to unhealthy levels. Please reconsider the harmful effects of the proposed legislation and remove it accordingly.
Todd Pettibon Comment On Regulatory Notice 22-08
Dear SEC, I'm vehemently opposed to Rule #S7-24-15, as it limits the available securities to the public which are within their right to own. As a licensed investment advisor, we already provide the expertise to our clients to explain leveraged and inverse funds as investments. Specifically, these are not recommended for every client, but can be quite useful for clients as a hedge, and should be available to the investor without a steep set of criteria that limits the market breadth and increases risk by reducing real market forces. Leveraged funds also enable the right investor to find more gains in otherwise flat returns, as long as prudently invested, representing no more than 1-2% of a portfolio. Research completed by knowledgable participants like Investment Advisors currently meets the criteria outlined in the proposed legislation, so it appears it is unnecessary, and potentially harmful by limiting the number of investors and consolidating markets which can distort valuation to unhealthy levels. Please reconsider the harmful effects of the proposed legislation and remove it accordingly.