Brian Lellis Comment On Regulatory Notice 22-08
Good Morning, I am writing this comment in response to your classification of LETF's as a complex product. I agree with this assertion, and additional warnings and barriers to investors using these products without prior understanding MIGHT be beneficial to "protecting" investors from themselves. However, I want to specifically advise that restrictions that prevent investors from opting into buying and holding these complex products, like the proposed 1 day buy and sell rule, are a bad idea. LETF's can be volatile products but encouraging through restrictions for investors to only be allowed to buy and hold them for a single day would cause additional harm as investors engaged in Day trading. I think investors should be educated on the risks but be allowed, after acknowledging their understanding of the risks, to invest in whatever complex or risky product they want, to allow equal access for all.