Once again, I have been Informed by ProShares that further restrictions are being considered on leveraged and inverse exchange traded funds. As I stated previously, these are among the best vehicles available in the market. I have made my living as an individual investor since February 1980. As I also stated, I have now used these vehicles for more than a decade and they have been consistently profitable in total. They are even more valuable in the current environment when there few opportunities to hedge current holdings or to seek profits. They provide an opportunity to seek profits on the market swings both up and down. I continue to work hard every day to try to get better and my investing strategies will continue to evolve. As I also stated, I use these funds in many different ways. I use them as a better alternative to options and margin borrowing. I use them to gain better access to global markets than I would have otherwise. I use them to access alternative asset classes which I would not be able to do otherwise in a cost effective manner, such as commodities and currencies (ProShares Trust II). In this respect, I want to see more sponsors and more vehicles NOT more requirements and more restrictions. As I also stated, current regulations offer ample protections and likely dissuade more risk averse investors from using these vehicles, to their detriment. One of the things I value the most about these vehicles is that they provide me leverage, while allowing me to maintain whatever cash position I choose, which is particularly important at this time, not to mention No Margin Calls. At the time, my positions in these vehicles amounted to 2-5% of my portfolio, now its more like 5% plus, reflective of the value they hold for me. I stated at the time that the SEC should declare victory and move on to something they really needed to do, such as repeal the abusive and detrimental Mutual Fund 203-b fees, which should have never been approved in the first place. I'm still waiting, and now the SEC comes back again with this! Free Minds and Free Markets!
Kenneth Church Comment On Regulatory Notice 22-08
Once again, I have been Informed by ProShares that further restrictions are being considered on leveraged and inverse exchange traded funds. As I stated previously, these are among the best vehicles available in the market. I have made my living as an individual investor since February 1980. As I also stated, I have now used these vehicles for more than a decade and they have been consistently profitable in total. They are even more valuable in the current environment when there few opportunities to hedge current holdings or to seek profits. They provide an opportunity to seek profits on the market swings both up and down. I continue to work hard every day to try to get better and my investing strategies will continue to evolve. As I also stated, I use these funds in many different ways. I use them as a better alternative to options and margin borrowing. I use them to gain better access to global markets than I would have otherwise. I use them to access alternative asset classes which I would not be able to do otherwise in a cost effective manner, such as commodities and currencies (ProShares Trust II). In this respect, I want to see more sponsors and more vehicles NOT more requirements and more restrictions. As I also stated, current regulations offer ample protections and likely dissuade more risk averse investors from using these vehicles, to their detriment. One of the things I value the most about these vehicles is that they provide me leverage, while allowing me to maintain whatever cash position I choose, which is particularly important at this time, not to mention No Margin Calls. At the time, my positions in these vehicles amounted to 2-5% of my portfolio, now its more like 5% plus, reflective of the value they hold for me. I stated at the time that the SEC should declare victory and move on to something they really needed to do, such as repeal the abusive and detrimental Mutual Fund 203-b fees, which should have never been approved in the first place. I'm still waiting, and now the SEC comes back again with this! Free Minds and Free Markets!