Subject: N/A
From: Martin Heilweil

Mar. 17, 2020

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

re SEC proposed #S7-24-15 

I have been using leveraged ETFs for ten years. I am very happy. 

I have no idea what the problem is, nor do I see any presentation of what the problem is. 

Every investment has the possibility of zeroing out. 

Anyone who does not accept the zero outcome, has no business in finance. 

Of course putting your money under your mattress has the risk of the house burning down. 

Government securities are at risk for sovereign repudiation. 

Metals are at risk for abandonment of the shared dementia of gold standards. If we find a new gold strike under the ocean, or find a cheap way to turn CO2 into gold, the global economy will founder. 

Breathing has risks. 

Life is risk. Otherwise go home and put your head under a pillow. 
Nothing in public documents links the nominal required information, ie personal financial portfolio/profile, with the proposed investor competence evaluation. 

And, given the risk/ reward calculations implicit or explicit, there is no metric on relative risk, 


that is, higher risk is often the preferred policy; 

we have a sports metaphor, from basketball - you miss 100% of the shots you don't take. 

I am looking at: 

This is 456 pages, and asks 250 specific questions, - 
If I am not able to master an ETF risk-disclosure document, I will certainly be unable to master this, so this falls afoul of the very guidelines you purport to affirm, informed participation - 

and provides 60 days to answer, or four questions per day, or if one works a five-day work-week, 60 days becomes about 40 days, for 250 questions, six per day, with about 456 pages /40 pages or ten per day, asking research and 800 footnotes , each to be evaluated, this is not a valid time frame and so is pro forma and not substantive. 

You also include estimates of $100 millions in compliance costs, which is prohibitive and not serious. 

Martin Heilweil