Subject: N/A
From: Myron Fuller

Mar. 17, 2020

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

Please do not get rid of leveraged ETFs. I've used the ProShares 2x S&P 500 ETF (SSO) for most of the last decade and have made a tremendous amount of money using it. Yes, it has a higher standard deviation than an unleveraged S&P 500 fund, but the stock market has an upward bias over time (and will likely always have one or the economy has bigger problems than leveraged ETFs). For those willing to bear the extra volatility over the short term, the additional gains can be tremendous over the long term. This is not just due to the 2x leverage but also due to the compounding that occurs over time. A 2x leveraged fund like SSO would have made roughly 24000% since I was born (7/17/1980) vs. 2600% for an unleveraged S&P 500 fund (not including dividends). That includes going through the 1981-1982 bear market, the 1987 crash, the 1990 recession, the 2000-2002 tech crash, and the 2008 financial crisis. Even since SSO was launched in 2006 it is up almost 400% vs. 164% for the market (even with the 2008 decline). I understand the desire to protect retail investors from themselves, but there are plenty of retail investors out here (including me) who fully understand the risks and use these as a core part of their investment strategy. 

Myron Fuller