Subject: N/A
From: Paul Ingbretsen

Mar. 17, 2020

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

I have been trading Direxion L&I Funds almost since their existence. They are the best of the leveraged products and most liquid products out there. They are of great advantage to trend traders with small accounts. I have been trading for over 22 years rarely risking more than 2% of available funds on any single trade. They are the only option (no pun intended) available to small account traders other than the highly volatile options market. 

The belief that investors cannot be trusted to understand clearly disclosed risks is an unprecedented, alarming and notable departure from the bedrock principles of the capital markets and of how the SEC regulates the offering of other securities.