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Frederic Huber Comment On Regulatory Notice 22-08

I have invested for 30 years. I have used inverse etfs to protect my investments in markets that decline, often because of government actions.

No one should have to pass a test administered by the government to protect their own finances.

This is overreach by a department that I do not believe is looking after my best interests. It is pursuing an agenda that is against my best interests.

Samuel Hwang Comment On Regulatory Notice 22-08

Leveraged funds and ETF's are important tools to allow investors to gain market leverage at a manageable level of risk, compared to traditional methods of leverage, such as the use of margin. Investors who research and learn the appropriate use of leveraged funds are able to use them as a part of an overall portfolio and generate leverage without jeopardizing their entire net worth. In comparison, the use of margin may result in greater losses than the investor's initial capital. Therefore, it is essential for retail investor to keep their full access to leveraged funds.