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Edward Dougherty Comment On Regulatory Notice 22-08

Given that our government continues to promote low interest rate environments where elder savers are punished, inverse etfs are an excellent tool to hedge income based stock portfolios. Instead of focusing on singular market events to evaluate etf tracking error, the government should endeavor to actually study long term inverse etf tracking error and counter party risk. Leveraged etfs are dangerous and might need more regulation, But Finra would be better off spending time on rules for crypto and new retail brokerage apps (read Robinhood).

Anthony Beirne Comment On Regulatory Notice 22-08

It makes no sense to me for regulators to restrict access to leveraged and inverse funds to accredited investors. I am an accredited investor for many purposes but earlier in my investing career, I was well aware of the risks of leverage but because such funds were rare, I was unable to access them without incurring substantial margin debt. Similarly, investors need access to inverse funds when the risks of market declines are high as they presently are. This enables some hedging of my portfolio without liquidating long investments, which I am holding for long term investment purposes.

Bradon Van Leuven Comment On Regulatory Notice 22-08

The proposed rule will negatively impact many investors that don't meet the qualifications. The rule will only benefit the wealthy. Making qualifications on how people can spend their own money benefits only the rich and opens up channels of discrimination. I currently use a 3x leveraged inverse fund to hedge my portfolio. If the "demonstrate high net worth" is the same as the day trading on margin restrictions or higher, there is no way I would qualify. This will greatly impact my ability to hedge against a market downturn.