Subject: N/A
From: Lawrence Vock
Affiliation:

Mar. 17, 2020


Comment on SEC Proposed Rule #S7-24-15: 

To The SEC: 
I have used leveraged funds in my portfolio strategy for the last 8 years. It has helped me attain my desired exposure to equities and let me maintain a cash position for future investment when the market pulls back. 

It also has helped me in handling taxable accounts and tax deferred accounts. At this stage of my life, my balance in taxable accounts is far greater in tax deferred accounts. 

Over the past 8 years, I have purchased traditional shares (non leveraged) and acquired additional shares thru DRIPS in taxable accounts. I have not sold any of the positions. These positions would be considered a "buy and hold" approach. 

In my tax deferred accounts, I have a buy and hold position of leveraged securities. It allows me to have a position of equities and a position of cash. If and when the market (S&P index) drops a certain percentage from the market high, I can purchase additional leveraged securities. If and when the market returns to the previous market high, I can sell the recently purchased shares and return to cash. 

Please do not eliminate leveraged fund. They are extremely helpful in my allocation. 

Regards, 
Lawrence Vock