The commission should avoid to the maximum extent possible regulations that imply a judgment about the merits of a strategy, including risk assessment, portfolio construction , and asset selection. For example, if the commission set an upper bound on the volatility of a positive convexity ETF, this would be a blind and incorrect risk assessment judgment that short changes investors. The commission should strive actively to minimize judgments about risk, especially for novel ETFs, so long as disclosures are clear and not fraudulent. The commission should actively avoid cross application of lessons learned from equity ETFs to novel ETFs. ETPs that exclusively invest in assets that are not securities should not be a security regardless of the strategy used. If a sponsor decides later to add securities to the product, they should be able to then register as a security.