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Eric Kasten Comment On Regulatory Notice 22-08

Typically, loss due to investment in funds is limited to the amount an investor was willing to use for purchasing those funds. Investing in leveraged and inverse funds is a useful tool for individual investors as it provides a mechanism by which to improve ROI when regular funds may be doing poorly. In all cases investors should be doing some research and consideration of risk before investing in funds or stocks; inverse and leveraged funds are no different.

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.