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James Pieronek Comment On Regulatory Notice 22-08

James Pieronek
N/A

I have used leveraged and inverse funds for years without problems. I can understand the desire to provide increased protection for the retail investor, but that could be handled by using the existing system of trading levels that brokerage houses use to limit trading in options and futures. I would think that it would be appropriate to require investors desiring to purchase these ETFs to be at the trading level required for the lowest level to buy put and call options. That way they are required to have read the numerous documents outlining the risks involved.

Finally, if these ETFs become out of reach for retail investors, they may take it upon themselves to conjure up their own options-based strategies to achieve the same leveraged returns. I think that would be inherently more risky and prone to mistakes due to missed expirations and accidentally unbalanced entries and exits.