Vlad Znakharchuk Comment On Regulatory Notice 22-08
Unlawful
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I oppose to restrict the rights to invest proshares.
No restrictions
I've recently become aware that FINRA is considering implementing restrictions on my ability to invest in leveraged ETFs and/or inverse ETFs. I want to advise you of my opposition to these measures as being unnecessary. I am fully aware of the risks involved as they are already highlighted by my brokerage firm and disclosed by the funds in the prospectus.
Stop trying to limit investment options for individual investors! There is absolutely no good reason for this recent push to regulate inverse and leveraged ETFs. If people/hedge funds can use leverage and short markets in other ways then why not via ETF?! Unless for some reason you don't want individuals to have a convenient option to short or use leverage?? Bizarre use of your time. -Sean
Schwab has a detailed description of these funds that you have to read and agree to, and I fully understand the risks. For this reason, they should not be restricted.
I oppose restrictions on my rights to invest as I wish in public investments in regulated markets. I should be able to choose (without restriction) which investments are right for me, not just the privileged financial class. I shouldn't have to go through some special process or pass a test before having access to any public securities including, but not limited to: inverse funds, leveraged funds, etc. as they are critical to my overall portfolio. I am intellegent enough to understand the risks.
The only way to make money in a down market is by shorting stock, buying put options, or buying inverse ETFs. Inverse ETFs are the least risky. If you restrict one's access to inverse ETFs, you are forcing them into riskier trades.
Sir, Regulators shouldn't choose the investments for my family. We are adults who understand the risk of investing in leveraged funds. They are important to me for a portion of my portfolio. They help me hedge my investments against market moves. In conclusion, we do not need these regulations imposed on us. I hope you will consider the views of the many investors who use these leveraged and inverse funds.
This proposed rule is yet another misguided attempt to "protect" retail investors, while all it would do is limit retail investors options and increase the public's distrust towards institutional investors. While leveraged funds do experience greater volatility (and in turn risk), they are relatively easy to understand and give retail investors easier exposure to leverage than option or futures strategies. Inverse funds are sometimes the only way to gain exposure to certain assets (for example some inverse currency pair funds), and retail investors would lose access to this.