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Paul Sutton Comment On Regulatory Notice 22-08

Comments: I've been using leveraged ETFs for many years and am well aware of the added risk. My experience is that the risk of the leveraged vehicle is not much different than investing in individual stocks. It is easy find examples of stocks that are far more volatile than the leveraged product. For example, a two year chart of ROKU with TECL would show that the leveraged ETF was a much better choice. A two year chart with NVDA shows a similar return with the the leveraged product (150%). The advantage of the ETF of course is that there is greater diversification.