For the past decade I have invested a small fraction of my portfolio (between 1 and 4%) in leveraged mutual funds and ETFs. I realize that these are quite risky and that rebalancing is required. But a careful investor who is mathematically inclined is capable of handling them. The people you propose to prohibit from trading leverages funds are exactly those who should be able to continue doing so, with their own money. And the people you propose to allow to continue taking outsized risks are those who trade with the money of others; perhaps this should be prevented as the risk is borne by the investor and they, not an advisor or fund manager, should make the decision to accept it or not.
I would support common-sense restrictions, such as that designated retirement accounts should limit exposure to leveraged funds. I would consider 15% of account balances to be a reasonable limit, greater than I am likely to ever reach myself, yet low enough to prevent investors from wiping out their retirement savings. I would support additional disclosures presented to those adding these investments to an account for the first time, and required reminders to rebalance if the fraction of an account goes above the 15% limit, as this could happen in the presence of a limit enforced on transactions, due to market movements or withdrawals.
In contrast, non-retirement accounts should be free of any restriction. Regulators' goals should be to prevent deception, not to restrict freedom.
Richard Voigt Comment On Regulatory Notice 22-08
For the past decade I have invested a small fraction of my portfolio (between 1 and 4%) in leveraged mutual funds and ETFs. I realize that these are quite risky and that rebalancing is required. But a careful investor who is mathematically inclined is capable of handling them. The people you propose to prohibit from trading leverages funds are exactly those who should be able to continue doing so, with their own money. And the people you propose to allow to continue taking outsized risks are those who trade with the money of others; perhaps this should be prevented as the risk is borne by the investor and they, not an advisor or fund manager, should make the decision to accept it or not.
I would support common-sense restrictions, such as that designated retirement accounts should limit exposure to leveraged funds. I would consider 15% of account balances to be a reasonable limit, greater than I am likely to ever reach myself, yet low enough to prevent investors from wiping out their retirement savings. I would support additional disclosures presented to those adding these investments to an account for the first time, and required reminders to rebalance if the fraction of an account goes above the 15% limit, as this could happen in the presence of a limit enforced on transactions, due to market movements or withdrawals.
In contrast, non-retirement accounts should be free of any restriction. Regulators' goals should be to prevent deception, not to restrict freedom.