Subject: File No. S7-24-15
From: Philippe-Olivier Giroux

April 15, 2020

The changes are not necessary. I have been using leveraged funds for several years and before doing so, I have done extensive research to understand them and the associated risk. Though a fair amount of reading and research is needed to well understand leveraged funds, the necessary information is disclosed in a transparent way and readily available. As such, I feel I am given proper opportunity to do my own due diligence before choosing these instruments. Leveraged funds provide investing opportunities that are otherwise not available or hard (and expensive) to access for small investors who manage their own portfolio. Additional rules may unnecessarily compromise access to these opportunities. Thanks for considering my views