Mark Shryock Comment On Regulatory Notice 22-08
I believe access to these funds should not be limited, but I believe an understanding of the risks associated with their purchase should be affirmed by the purchaser. I am a retired Registered Investment Adviser and use inverse and leveraged products to hedge my personal accounts. This is an inexpensive approach to hedging that does not involve options trading. But I believe the ownership of these products has limited use and that they should not be held long-term in any account, due to price degradation when market indexes are relatively stable.