Kirby Scott Comment On Regulatory Notice 22-08
Please do not put restrictions on who can and cannot purchase leveraged funds. These types of investments should be made available to the public, not just the rich.
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Please do not put restrictions on who can and cannot purchase leveraged funds. These types of investments should be made available to the public, not just the rich.
I am a small private investor who uses inverse and leveraged funds to protect my modest portfolio from from adverse market moves. Hampering my ability to use these investment vehicles would be a travesty of freedom and unamerican. DO NOT hinder my ability to protect my family and my retirement funds from these form of protection. YES...protection! Because that is exactly how they are used by me and many investors I know.
I recognize that some investors do not fully appreciate the risks of investing in these funds. However, for investors who understand them, they represent one of the few ways non-high net worth investors can simulate the strategies of hedge funds restricted to high net worth individuals. They level the playing field especially inverse funds whose implicit interest rates are much lower than the margin rates charged by brokers to small investors.
We should have right to choose the public investments without any restrictions
Please do not over regulate my ability to invest as I see necessary.
I am a client associate at Merrill Lynch (soon to be registered client associate after passing my Series 7 and 66) and I recently passed the SIE. I fully understand the mechanisms behind leveraged/inverse products. Limiting the accessibility of these products is not in an individuals best interest because they should be allowed to make their own risk/reward judgements. 25% of my portfolio is allocated to triple leveraged funds to potentially enhance my returns without taking on an extraordinary level of risk.
As a 52 adult, I believe I am capable of assessing my own investments and risk profile. By erecting these hurdles, you disenfranchise common investors from taking advantage of investments that could make a real difference in their wealth. I genuinely don't need additional regulations imposed upon me to tell me what I already know about leveraged and inverse funds. I am capable of understanding their risks. These strategies allow me to take advantage of all market conditions, up or down, in a way that no other investments allow.
Do not restrict access to leveraged ETFs. These are the only way average investors can employ the same strategies as the billionaires you are actually trying to protect by limiting the rest of us.
I support FINRA's effort to curtail the purchase of leveraged and inverse funds and dozens of other popular investments deemed to be complex. These types of investments are nothing more than pure gambling. I applaud FINRA's action to protect the unwary investor.
As a regular investor, want to be allowed to buy leveraged and inverse funds and dozens of other popular investments deemed to be complex in the way adopted so far in each broker.