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Xiao Zhang Comment On Regulatory Notice 22-08

I am a Chartered Financial Analyst (CFA) holder with more than ten years of investment experience. I'm capable to manage the investment risk in my own portfolio. I do not need the regulators to choose the investments that is right for me. I have my own investment strategies that matches my risk tolerance. Leveraged funds are important to my strategies. They help me hedge my investment risks and obtain enhanced returns. I am capable of understanding these leveraged funds and their risks.

David Evaul Comment On Regulatory Notice 22-08

Triple and double leveraged etfs provide a simple and understandable way to hedge positions, or without personal leverage, create a larger upside position for an investor. Without well managed, liquid etfs, such investors would have to enter into the mysterious derivative and option strategies world that are beyond most everyone's ability to actually understand. Indeed such strategies would almost never match your hedging/investment goals (and probably would expose you to substantial unanticipated risks) as well as a simple etf strategy.

Michael Murdock Comment On Regulatory Notice 22-08

Dear FINRA,

I have successfully used leveraged (3x) ETFs as part of my investment strategy for many years now. They give me a safer way to capture large movements in the market than trading options would.

For example, if you buy a call option on the SPX, that investment could go to zero if you don't time your trade correctly.

However, when buying a 3x leveraged ETF like UPRO, your investment will not go to zero unless the S&P 500 itself goes to zero (which would be the end of the world).

Michelle Young Comment On Regulatory Notice 22-08

I oppose restriction to invest in public investments of leveraged and inverse funds.

We shouldn't have to go through special processes
like passing a test before we can invest in public securities,
like leveraged and inverse funds.
we are
capable of understanding leveraged and inverse funds
and their risks. I do not
need more measures imposed. We already sign a statement that we are aware of the risks. I feel that is enough!

Matthew Rohr Comment On Regulatory Notice 22-08

Dear FINRA,

I have been investing for many years, and have on many occasions used leveraged and inverse funds as part of a responsible portfolio management.

Restricting these products as you propose will remove important tools from the hands of small investors. Bluntly, these funds are not particularly complicated, and investors are not stupid. Furthermore, creating artificial barriers to their use by the general public will likely INCREASE volatility, exactly in opposition to your presumed goals.

Nicholas Gault Comment On Regulatory Notice 22-08

I am in favor of allowing the public to continue its access to leveraged and inverse funds such as ProShares/ProFunds. These funds are effective vehicles for hedging my portfolio. I fully understand the risks and choose to use these funds because they offer a simple way to hedge or leverage without getting into more complex vehicles like options or taking on margin debt. In my opinion, it is much more risky to use margin debt and options to achieve similar strategies as those enabled by inverse and leveraged funds.