Subject: N/A
From: Rolf Waller

Mar. 17, 2020

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

To whom it may concern: 

Please do not restrict the purchase of leveraged and inverse funds in any way. I have been using such funds for years to mitigate risk and to magnify trend results. In my opinion, both leveraged-fund issuers I've worked with - ProShares and Direxion - have provided ample information and even caution when marketing their products, and make it VERY clear that these investments can be extremely volatile. 

As the consumer, I do not go into these investments blindly, and I am very well aware of the risks AND benefits, largely because the warnings are made very obviously by the issuers. I have found many funds to be quite liquid, with price execution as normal as any ETF or ETN. Exiting positions is as efficient as selling any security, and there has never been a situation where I couldn't get out of a position when it no longer met my needs. 

The funds also provide diversification, but with the benefit of price performance similar to that of regular stocks. This quality is not found in standard funds, as their price movement is moderated by the sheer number of holdings. 

Thank you. 

Rolf Waller