March 10, 2020
Why create unnecessary red tape for investors and their registered broker dealers?
This is an example of regulatory overreach, where the vast majority are inconvenienced or possibly even prevented from accessing valid investment products (with embedded derivatives) that suit their risk vs return objectives.
I am strongly against the SEC proceeding with S7-24-15. It adds costs at the broker dealer level, time / filing hassle by investors, for little to no benefit.
Stop treating retail investors like children. Retail investors are aware of the risks they take on with leveraged and/or inverse investment vehicles, they can read. And having read the product disclosure statement, they can safely proceed with investing in the specific investment exposures that such products offer. No second checks, 3rd party evaluations or additional form filling required.
Stop curtailing investment freedom and frustrating product innovation at the investment vehicle level. The SEC hasn't proven a harm case, rather, this is just annoying. Cease and desist with S7-24-15, and focus on other more useful areas of market regulation.