Comments I, an educated and experienced investor for over 50 years, utilize Direxion leveraged and inverse ETFs for my portfolios. All Direxion leveraged and inverse ETFs are intended for investors as I, with an in-depth understanding of the risks associated with seeking leveraged investment results, and I do actively monitor and manage my positions. I am aware that there is no guarantee that these Funds will meet their objective.

We already sign disclosures at brokerages warning us about the potential dangers of leveraged products. This is a huge slap in the face for retail investors and a ton of unnecessary road blocks for us that would separate us even further from institutional investors. The HUGE detrimental affect this would have on me would be insurmountable. I have leveraged ETF positions that are currently in the negative due to the recent market downturn, but that I whole heartedly know will rebound when the market recovers.

I would like to say that I like the Leveraged and Inverse Funds from Derexion. They allow the regular investor a change to trade both sides of the market. This is critical because of machine trading by Hedge funds. Thanks Greg Maher

Comments: I would be against limiting access to the leveraged indexes. These provide both diversity for small investors, while providing outsized returns at a lower cost than mutual funds. The TQQQ grew from $19 in March 2020 to $200 by Jan 2021 before a 2/1 split. It was up 1200% from Sept 2016 to Sept 2021. If FINRA is really looking out for investors, how is limiting such returns in the interests of small investors? Buying DIG a 2x oil ETF in Nov 2020 at $17 which then went up on the reopening of the economy to $157 on April 18, 2022... a return 9 fold in just 18 months.

Yes I ask that FINRA puts limit on how much money can be invested in L&I funds, it should be no more that 20% of portfolio, brokerage should limit purchase in this funds as these are extremely high risk funds that most investors do not understand. Sending a disclosure does not help as most people do not read it or undersand the language, it should be restricted by brokerage.

Comments: I am a licensed 6,7,63,65 FA, it has been 17 years since I passed my series 6 exam. I have a BS in Business and a MBA. I have almost 30 years of banking and finance experience. Leveraged ETFs are misunderstood and misevaluated by regulators and investors. If you examine the returns of leveraged ETFs that track major indices you will find that while they do not offer a superior "risk adjusted return", they do offer unprecedented returns in terms of total dollar returns. For example, if you invested $10,000 into SPXL in 12/2008 (inception) today you have close to $500k.

Enhancement to current rules

Comments: Access to Leveraged and Inverse ETFs should continue.

I have held Direxion leveraged ETF's for over 10 years, understand the risks as outlined, and have had no problem accepting the results of anticipating the market direction in specific areas. There are plenty of educational materials available. Don't fix what really isn't broke.

There is no need for any further regulation of leveraged or inverse ETF's. The risks of these products are widely known and understood by the vast majority of investor. It should be noted that they are no more risky than some of the "penny stocks" or "junk bonds" that currently trade. Despite using leverage, they are often less leveraged than many publicly traded companies.