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.

I understand the risks involved in leveraged investments and I am fully capable of using such instruments in my portfolio to increase the diversity and return of my accounts. All investments carry risks and I have used leveraged funds for over ten years. I should not be required to take any tests or special processes as I feel comfortable and accomplished that my experience and portfolio demonstrate a clear understanding of all risks. Leveraged funds are an integral part of my portfolio that I rely on to increase my return.

I am writing to oppose the radical limitations on my investments proposed by the Financial Industry Regulatory Authority (FINRA). Under the long-standing disclosure-based system, investors have the right to decide which public equities, bonds, and funds they want to buy. The freedom to access a broad range of investment products help me build better portfolios and limit my risks in the market. FINRAs definition of complex products is so broad, arbitrary, and vague that it could invalidate persons from a vast number of commonly used public securities.