I have been using some of the double leveraged products for a decade now. For long term investors (e.g. 10, 20, or even 30 years), they can make a lot of sense to improve returns. For example, if you invest 10% of your money today in a 2x product like SSO, your total annual return will be about 30/percent higher than just investing in the S&P 500 index. If you have that sort of time rising, you can take the rest. I
Alternatively, short-term traders have access to futures which are much more leveraged than these products. So I am not sure how you are taking risk out by putting further limitations on these products.
Tom Chorba Comment On Regulatory Notice 22-08
I have been using some of the double leveraged products for a decade now. For long term investors (e.g. 10, 20, or even 30 years), they can make a lot of sense to improve returns. For example, if you invest 10% of your money today in a 2x product like SSO, your total annual return will be about 30/percent higher than just investing in the S&P 500 index. If you have that sort of time rising, you can take the rest. I
Alternatively, short-term traders have access to futures which are much more leveraged than these products. So I am not sure how you are taking risk out by putting further limitations on these products.