May. 10, 2021
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Jay Clayton, Chair SEC Headquarters 100 F Street, NE Washington, DC 20549 (202) 551-2100 chairmanoffice@sec.gov Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 rule-comments@sec.gov Re: Proposed Rule Change to List and Trade Shares of the 2x Long VIX Futures ETF; Proposed Rule Change to List and Trade Shares of the -1x Short Futures ETF Dear Chairman and Secretary: AFR submitted a comment letter, https://protect2.fireeye.com/v1/url?k=9e7f6ddc-c1e4552a-9e7f896a-8681010e5614-ff972451594dada3&q=1&e=8082edb3-bd59-4fc8-80af-bf589000c36a&u=https%3A%2F%2Fourfinancialsecurity.org%2Fwp-content%2Fuploads%2F2021%2F05%2FLeveraged-VIX-ETF-Comment-Letter-FINAL.pdf, urging that the Commission against approving yet another unnecessary leveraged ETF based on the Chicago Board of Exchange (CBOE) Volatility Index of the S&P 500 (“VIX”). The letter raises important concerns about not only the inherent dangers of leveraged ETFs that make them unsuitable investments for retail investors but also the systemic risks around managing another volatility ETF reminiscent of the “Volmageddon” episode back on February 5, 2018. Given that these products clearly pose risk to investors and do not provide clear benefits for capital formation, approving them would conflict with the SEC’s mission. While other such risky and synthetic products already exist, this is not a reason to add to the problem. Instead, the Commission should reconsider its overall approach to complex exchange-traded products. Yours sincerely. Robert E. Rutkowski