Publication Date: February 23, 2023
Interpretations are marked in blue background beneath the rule text to which they relate.
15c3-1f Optional market and credit risk requirements for OTC derivatives dealers (Appendix F to 17 CFR 240.15c3-1).
15c3-1f(a) Application Requirements
An OTC derivatives dealer may apply to the Commission for authorization to compute capital charges for market and
Comments: Please do not get rid of leveraged inverse etfs. It gives people with less capital a chance to hedge their existing positions and even profit off the losses in their existing stock. The rich will always get richer in these situations, you will only be taking away our opportunity to make money in those situations.
I cannot express in the strongest of terms that it is my right as an individual investor to have the freedom to analyze macro-economic conditions and make investment choices that protect/grow my capital. This includes the possible need to invest in leveraged and inverse funds if the market conditions call for it with all the individual risks that go with personal ownership of alternative
The ability to trade inverse ETFs (easier to capitalize on a downward market for novice trader) and utilize leverage helps to encourage market participation by people in all income brackets. To take away these options would be a stride towards exclusivity based on economic status and further separate already diverging income classes and political parties.
As an investor we understand risks associated with investing in leveraged and inverse funds. Please do not restrict investors(esp retail) and make investing in stock market tougher. This regulations if brought in will impact investors/traders who are already in trading and they might incur huge loss in terms of capital depreciation by scaring away exiting and new investments.
Market manipulation has been there over decades. Traditional retailers is suffering more than anytime due to the leverage of capital that’s not based on equal ruling. On top, law enforcement agency has not been obligated with the assigned duty. When will an open and fair market/system be back?
Leveraged and inverse funds are important part of risk management. These funds make it possible to use a small percentage of capital to risk manage the other side of a trade. There are plenty of SEC / FINRA regulation as well as documentation on investments to understand the risk. Should investors ignore reading the documents of any and all investments that is the investors choice.
Please do not restrict investor access to complex and leveraged products. Yes, there ought to be disclosures of risks and transparency around fund mechanisms. In other words: informed consent. But barring access is undemocratic and wrong. Many leveraged funds are useful tools for investors who lack the requisite capital to use futures to achieve leverage.
Ive been investing for almost a decade. I understand the risk of using leveraged and inverse ETFs. I am making the choice to trade them with the understanding that I can lose a lot of capital but I should be allowed to make my own decision. Cigarettes and alcohol are far riskier than trading stocks, but theyre still bought and sold.
FINRA Requests Comment on Proposed Exemption to the Trading Activity Fee for Proprietary Trading Firms
