Subject: Comment on File No. S7-24-15
From: Roger Radke

Feb. 17, 2020


Dear Madam, Sir,
recently I received notification that the Securities and Exchange Commission is considering a proposal that would make it “more burdensome to buy, or even prevent you from buying, leveraged and inverse funds …” 
Apparently the SEC has received complaints from investors who lost money by using leveraged funds improperly, despite widespread reporting (and sometimes condemnation) in financial media for the fact that their daily magnification of index movements does not lend itself in some time frames to the buy-and-hold plans that work for non-leveraged index funds. 
I have been using leveraged ETF’s for several years as part of a systematic investment plan that employs quarterly rebalancing between stock and bond funds. Though not a financial professional, I consider myself a prudent and risk-averse investor with leveraged products being a key part of my financial plan. These funds have improved my performance over the long term. I have never been interested in short-term trading and understand the effect of daily magnification of an index’s price movement. In fact, I have used that to my advantage.
I do not want a third party evaluating my capability of managing these funds, and certainly do not want one preventing me from buying them. If leveraged funds are restricted to accredited or wealthy investors only, the wealth gap in the country will further increase as the rich get richer in sophisticated products while everybody else languishes in plain old index funds. 
Please keep leveraged funds available to all investors. 
Dr. Roger Radke