Lu Zang Comment On Regulatory Notice 22-08
It is an investors right to freely access the entirety of the public securities markets without arbitrary restrictions,
For the Public
FINRA Data provides non-commercial use of data, specifically the ability to save data views and create and manage a Bond Watchlist.
For Industry Professionals
Registered representatives can fulfill Continuing Education requirements, view their industry CRD record and perform other compliance tasks.
For Member Firms
Firm compliance professionals can access filings and requests, run reports and submit support tickets.
It is an investors right to freely access the entirety of the public securities markets without arbitrary restrictions,
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.
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.
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).
Any attempt to restrict or limit my ability to invest or otherwise interact with the economic and financial institutions of this country will be considered an action worthy of rebellion.
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!
As an individual investor, it is important to me to be able to invest in leveraged and inverse products to design and manage my retirement investment portfolios to minimize risk and drawdown over long-term economic periods. Please continue to allow these products to be accessed.
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.
Leveraged and inverse ETFs are an extremely efficient and effective way to both hedge my core holdings, and to share in momentum moves. Please do not restrict my access to them, or the time frame I'm permitted to hold or trade these funds. Thank you.
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.