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Joseph Chou Comment On Regulatory Notice 22-08

To FINRA,

As a professional in the investment industry, I strongly feel the disclosures regarding investment performance and risk are well communicated and transparent regarding leveraged ETFs. It is very simple to understand those products that have 2x or 3x leveraged being specified as DAILY performance.

To limit the ability to invest in those products or to remove them completely would create great price distortion, as well as liquidity problems for existing investors such as myself.

Matthew Dolan Comment On Regulatory Notice 22-08

To whom it may concern,

I'm writing to express my dismay at the consideration of this proposal. Attempting to restrict the ability of the average American to access specific investment classes is overly-restrictive and represents a fundamental distrust of the intelligence of the people. Those that are willing to pursue an opportunity should only be limited by their own abilities, and not by overregulation. I strongly oppose this proposal as being directly against the interests of the American people.

Gregory Braden Comment On Regulatory Notice 22-08

Please do not place new restrictions on leveraged or inverse ETFs and traditional mutual funds.

As mutual funds, both ETFs and traditionals are well-regulated and their fee structures are transparent. They are also easy to use through many brokerages.

For an investor who at times wants to use leverage or an inverse position for a short period of time, inverse and leveraged mutual funds are the most convenient way to do so -- compared to, for example, shorting securities or purchasing derivatives (puts) or swaps, which are much more complicated to trade.

Ross Libman Comment On Regulatory Notice 22-08

As long as the prospectus of the ETF is documented and the fund manager is able to maintain the daily tracking detailed, there should not be additional regulation upon public securities. Having access to specialized products allows knowledgeable investors to properly allocate to their portfolios outside of options or futures, which require higher risk management capacities in comparison to leveraged or inverse ETFs.