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Malcolm Cutchin Comment On Regulatory Notice 22-08

I use leveraged funds to hedge my accounts in volatile markets. They are a particularly efficient and inexpensive way to do that in a short-term way. Regulations make short-selling as a hedge very difficult and cumbersome; the ability to access leveraged ETFs levels the playing field for retail investors who do not use brokers. I understand the risks and decay of the instruments, but those are minimal when used as short term hedges. If one can buy options, why not leveraged ETFs? I really want to maintain the freedom of access to such ETFs.

Michael Carroll Comment On Regulatory Notice 22-08

Leveraged funds are diversified to begin with offsetting risk. If folks want to lever them 2x or 3x that's still far less risky than buying an individual stock. Given other issues in the markets it's baffling regulators are focus on funds and not out of the money options or crypto as real issues that can affect investors who aren't as experiences. As a former professional trader, this is backwards and not focused on the greater good, I don't know what it is focused on honestly.

Curtis Winterfeld Comment On Regulatory Notice 22-08

Required labeling and disclosure of a fund's use of leverage and inverse strategies is sufficient information for the majority of investors. Regulatory focus should be on the transparency of the labeling and the sufficiency of the disclosure required of these funds. Ultimately, government cannot protect a person from his/her poor judgement, hubris, or greed; a person bent on failure will always find a way. Don't limit the rest of us from using these investment tools.