James G Comment On Regulatory Notice 22-08
Srongly believe the proposed regulations are: Bad for Investors. If the proposal is adopted, some investors who could benefit from the enhanced return and portfolio protection potential of leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process. Brokerage firms could even stop offering these funds altogether due to the difficulty of implementing the regulations. Unnecessary. The SEC has not shown there is a problem that needs to be solved with respect to leveraged and inverse funds.