Subject: N/A
From: Akito Matsumoto

Mar. 17, 2020


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

Leveraged ETF creates a nice vehicle to use leverage without getting margin. If I borrow to lever it will be more costly and more risky because I can lose more than I invested. 

Reverse ETF provides an easy way to get short position with limited loss. 

In sum, these ETFs are safer than borrow to lever and go short on margins. Thanks 

Akito Matsumoto