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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.