Subject: S7-24-15: WebForm Comments from BAJAJ, PUNEET
Affiliation: Professional - IIT (Bachelors) STANFORD (Masters) Graduate.

Jan. 30, 2020

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Comments of P. BAJAJ on S7-24-15

Comments of PUNEET BAJAJ, Professional - IIT (Bachelors)  STANFORD (Masters) Graduate. , BANGALORE, India
Time: January 30, 2020
href: /comments/S7-24-15/S72415-nnnn.htm
file: S72415-nnnn.htm
Uploaded href 1: /comments/S7-24-15/pbajaj4269.pdf
Uploaded file 1: pbajaj4269.pdf

   Subject: File No. S7-24-15
   Affiliation: Professional - IIT (Bachelors) STANFORD (Masters)

   January 30, 2020

   Item 1: General Identifying Information

   a. Is the firm a Commission-registered investment adviser or a
   broker-dealer?: NO. Just a regular Individual Investor, benefiting
   from Top Leveraged-ETFs. +60% in 6-months. Understand the downside
   risks FULLY.

   b. What is the size of the firm in terms of:
   1.) The number of retail investors (as defined in the release)? 0
   2.) For Investment Advisers, regulatory assets under management? 0
   3.) For broker-dealers, regulatory net capital? 0
   4.) Other (please specify)? Individual Investor - $60,000 Invested

   c. Please include any additional general identifying information that
   you wish to provide, that could add context to your other feedback on
   the proposal.

   5+ Years of US Market Experience (Fidelity Account), Benefiting from
   Leveraged-ETFs since 2018. Returns +60% in 6-months, from
   Leveraged-ETFs (Net-worth $40,000-to-$63,000 from Jun2019-Jan2020).
   These products are great for small investors, as we cannot invest
   MILLIONs-of-Dollars for ordinary returns.

   d. Does the firm accept orders from or place orders for the accounts
   of retail investors to buy or sell shares of leveraged/inverse
   investment vehicles (as defined in the proposed sales practices

   Item 2: Cost to Comply with the Proposed Due Diligence and Account
   Approval Requirements

   a. What do you expect the cost to your firm would be in order to
   comply with these proposed requirements (in terms of combined internal
   and external costs)?
   1.) For an investment adviser (check one box):

   2.) For a broker-dealer (check one box):

   b. Are there any less expensive alternatives to the proposed
   requirements you can suggest that would still preserve the proposed
   rules intended investor protection safeguards?

   Maintain the Level of Due Diligence as required for "Options Selling"
   approval, as Leveraged ETFs are NOT More riskier than those, in-fact
   MUCH less risky, as the Max loss is limited to the amount invested.
   And nobody in their sane mind will bet their house on such products.
   But with HUGE multiples in the long runs, 20x-to-50x in 10 Years (real
   performance), they definitely hold a small position in the Long Term

   Such Exceptional performance is being generated with their smart
   design, and a lot of investor education is available online for the

   Item 3: Other Feedback on Proposed Sales Practices Rules

   Instructions: Please include any other additional suggestions or
   comments about the proposed sales practices rules that you would like
   to provide.

   There is a lot of education available to Investors online, please
   encourage better education.

   Additionally, we also believe that some big Fund Managers, or Lobbies,
   might be interested in putting these down, as otherwise they CAN NOT
   beat their long term performance (not even come close).

   So, rather than helping clients to TIME their investments into these,
   they might resort to have these blocked, just because some
   NOT-SO-SMART-PRODUCTS bombed here there.

   (Attached File #1: pbajaj4269.pdf)

INDEX Entry:

<tr onMouseOver="this.bgcolor='#E0E0E0'" on MouseOut="this.bgColor='#FFFFFF'" bgcolor="#FFFFFF" valign="top">
<td nowrap>Jan. 30, 2020</td>
<td><a href="/comments/S7-24-15/S72415-nnnn.htm" class="subCat9">PUNEET BAJAJ, Professional - IIT (Bachelors)  STANFORD (Masters) Graduate. , BANGALORE, India</a></td></tr>

(Attached File #1:s72415-6722961-206759.pdf)