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Eliajah Hunsaker Comment On Regulatory Notice 22-08

Eliajah Hunsaker

LETFs are indeed complex investment instruments but I believe current disclosure requirements are more than sufficient for investors to remain informed about the products they are buying. Limiting the purchase of LETF products to accredited investors or requiring financial literacy tests to purchase only puts unnecessary roadblocks in place that are easily circumvented. Enforcing one day holding limits will force myself and others to realize massive amounts of capital gains taxes and force us to utilize less efficient (and frankly more dangerous) forms of synthetic leverage to replicate our current leveraged efficient portfolio buy and hold strategies.