Skip to main content

Gordon Charles Comment On Regulatory Notice 22-08

Gordon Charles
N/A

I can understand the goal of protecting novice investors from complex investment tools they lack the sophistication to understand; however, requiring vendors to supply documents to educate the investment community and requiring users to sign off on having reviewed those documents should be the limit of any requirements. Restricting access based upon net worth is absurd.

In addition many leveraged ETFs are actually very safe vehicles; offering reasonable returns at low risk. In the history of the market ETFs such as Proshares QLD (2x NADAQ) consistently outperforms the majority of investment options, yet is based upon an index rebalancing scheme, keeping low overhead. Removing the availability of a fund like this is lumping in a safe and effective vehicle with other vehicles which may be high risk and clearly not in the benefit of the investment community at large.