This action is not based on any evidence of misuse of leveraged ETFs. Arguably, this action would push investors into far riskier investments such as cryptocurrencies, margin trading, short term options, and penny stocks - why draw the line at leveraged ETFs? Utilizing a leveraged ETF tracking DOW30 and S&P500 as a small percentage of my portfolio helps me enhance my returns. Leveraged ETFs, when used wisely, not only enhance returns, but enable the use of leverage, while being lower maintenance over margin trading when wanting to maintain targeted ratios (this is arguably safer than margin trading which can lead to total bankruptcy from margin calls in bear markets). Leveraged ETFs, when following a Dollar-Cost-Average strategy with a fraction of my portfolio, enhance my long-term returns, but they are also helpful as short-term hedges. For example, investing in TMV this year as rates hiked helped balance out the impact on my long UPRO/UDOW positions. Leveraged ETFs should not be limited to only wealthy investors, who have exclusive access to multiple alternative investment vehicles such as angel investing, venture capital, and private equity. The proposed action is yet another way the government can make even more investment vehicles exclusive to the wealthy, and drive wealth inequality. Banning leveraged ETFs is especially deadly in the current bearish market climate, as forcing liquidation of these assets right now is exactly what responsible leveraged ETF investors would not do. I would not sell my long positions in UDOW/UPRO any time soon, and would disapprove any ban. Finally, the proposed action by FINRA is an infringement on investors' individual liberties, and runs contrary to our republics values. Investors of all backgrounds should be able to make investments that are right for themselves and their families, without government interference.
Varun Sriram Comment On Regulatory Notice 22-08
This action is not based on any evidence of misuse of leveraged ETFs. Arguably, this action would push investors into far riskier investments such as cryptocurrencies, margin trading, short term options, and penny stocks - why draw the line at leveraged ETFs? Utilizing a leveraged ETF tracking DOW30 and S&P500 as a small percentage of my portfolio helps me enhance my returns. Leveraged ETFs, when used wisely, not only enhance returns, but enable the use of leverage, while being lower maintenance over margin trading when wanting to maintain targeted ratios (this is arguably safer than margin trading which can lead to total bankruptcy from margin calls in bear markets). Leveraged ETFs, when following a Dollar-Cost-Average strategy with a fraction of my portfolio, enhance my long-term returns, but they are also helpful as short-term hedges. For example, investing in TMV this year as rates hiked helped balance out the impact on my long UPRO/UDOW positions. Leveraged ETFs should not be limited to only wealthy investors, who have exclusive access to multiple alternative investment vehicles such as angel investing, venture capital, and private equity. The proposed action is yet another way the government can make even more investment vehicles exclusive to the wealthy, and drive wealth inequality. Banning leveraged ETFs is especially deadly in the current bearish market climate, as forcing liquidation of these assets right now is exactly what responsible leveraged ETF investors would not do. I would not sell my long positions in UDOW/UPRO any time soon, and would disapprove any ban. Finally, the proposed action by FINRA is an infringement on investors' individual liberties, and runs contrary to our republics values. Investors of all backgrounds should be able to make investments that are right for themselves and their families, without government interference.