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Todd Miller Comment On Regulatory Notice 22-08

This is really not going to help individual retail investors. Lots of retail investors would be losing valuable hedging and speculating tools in terms of leveraged and inverse ETF's. Many of these investors may utilize cash accounts and have no other way to go short in the market without buying put options, which is another layer of approval. As such, ETF's are the most accessible and easy to trade and least complex of hedging instruments and to put these kind of access restrictions is mind-boggling.

Don Anderson Comment On Regulatory Notice 22-08

I have managed my investments for over 60 years. I have studied and invested in broad market, leveraged and inverse ETFs for the past 15 years. I use them to manage risk.

The restrictions proposed would reduce the liquidity in these ETFs and render them dangerous to use. Any regulation of these securities should strive to improve openness and knowledge of the products, promote open and liquid markets, and control contra-party stability and risk. Your proposal dose not address any of these issues.