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Bill Hannigan Comment On Regulatory Notice 22-08

Comments: Active investors are fully aware of the advantages and disadvantages of the instruments they invest in - most seek advice or read up on how they function. Exchange Traded Funds (ETFs) are by no means, whether regular or inverse, complicated in how they move with the indices or stocks they hold. The calculation of leveraged funds is complex; however, investors fully understand how they move with the underlying markets. Regulation might assist in protection from the asset's value being disproportionate to market moves.

Michael McBride Comment On Regulatory Notice 22-08

Comments: I have been using these type of accounts for awhile now. If used sparingly and watch closely they can enhance your porfolio. There is inherent risk, but that is with everything. These don't really move any different than any index funds. They allow you the flexibility and protection at times of turbulence in the markets. I would never suggest anyone putting a large percentage into any one stock or even index. So, use it to add to your portfolio don't make them your portfolio. That's exactly what Direxion says as well.

C. Torian Comment On Regulatory Notice 22-08

Dear FINRA Policy Makers: ETFs and complex inverse and leveraged ETFs have now been around for almost two decades. Why do you want to make "enhancements" that are actually are in fact "detractions" for individual investors and put them BACK into a position of not having access to ways to protect their portfolios, use hedging strategies without having significant amount of knowledge of various options strategies, and actually use LESS dollars to have an overweight position in a particular market, sector or strategy?