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Len Mei Comment On Regulatory Notice 22-08

Len Mei
N/A

Dear sirs

Thank you for letting me know your consideration of leveraged ETF. I am testing an investment strategy using leveraged ETF. According to my extensive simulation, the strategy itself does not represent higher risk. But short term wise, it can fluctuate a lot. The reward is better than the market average. Therefore, the risk/ reward ratio is low.

ETF of market does not have the risk of individual company. Leverage ETF has higher risk than the market ETF, acknowledged. Combining money management and timing, it can be profitable over the long haul.

In addition, the trading of my strategy is short term. It does not hold a position for long. However, the strategy itself is long term. It may suffer short term loss, but long term prospect is good, from my simulation.

In addition, I have faith in the stock market. Every major downturn turns out to be a buying opportunity, including 2008. This is especially true in the high tech market, which reflects the 4th industrial revolution, and the digital economy. The U.S. digital economy is growing at 10% rate, much higher than the general economy. That is a fact. I have tested many parameters and decided that it is worthwhile a try.

I have Ph.D. degree in engineering and have invested in stock for over 40 years.