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Jonathan Dubin Comment On Regulatory Notice 22-08

Comments:

While optics are ever present around good consumer advocacy policy, creating regulatory burden is not a good way to go about this.

In the strong capitalistic financial environment that the US exists in, retail investors should have the ability to put their money in Leveraged-Inverse ETFs if they so choose as long as they are aware of the long-term risks of holding such financial products.

Kelon Morley Comment On Regulatory Notice 22-08

Comments:
As an individual investor who relies on leveraged and inverse ETFs to actively monitor and manage short term trading strategies, these instruments are critical to compliment more conventional products while providing desired exposure to targeted segments of the market. Notably, leveraged and inverse ETFs also provide an effective means to hedge other more conventional positions. The risks associated with leveraged and inverse ETFs are clearly identified by their providers and do not require additional regulatory complexity.