Subject: N/A

Mar. 17, 2020

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

Very unfortunate to see the US going the Archaic way. What is clearly a GREAT US Differentiator (ExoticETFs), vested interests might take it away. 

I am a Fidelity Account holder (****4620), having 5 Years+ of US Market experience, & Am benefiting IMMENSELY from #UPRO & #TQQQ type ExoticETFs, having returns of +60% & +100% in them (since Jun-2019), and a $40,000 portfolio becoming $60,000+, after the markets broke out in Oct 2019. 

Usually ONLY SMART INVESTORS invest in such products, who have deeper understanding of the markets. UPRO & TQQQ have multiplied 25x or 50x in the past 10 Years (working exactly as designed), so they definitely hold a small position in my Long Term portfolio. Uneducated people should educate themselves on the Markets & Technicals etc., to time their investing. 

Additionally, that XIV ETN (from Credit Suisse) that blew up (-99% in 2018) ... was a NOT a great investment to begin with, as any KID in the market knows that VOLATILITY can spike hugely on any day, out of the blue. So when Volatility spiked HUGELY in 1Q2018, VIX = +30-40%, and XIV (or SVXY) ETFs being the -3x Inverse ETFs on Volatility did -90% to -100%. THEY WORKED EXACTLY AS DESIGNED. Un-educated & ILL-INFORMED investors lost money, & should blame their advisors, or their lack of knowledge. 

Assuming that ALL LEVERAGED ETFs will blow up like XIV, is sheers Stupidity. 

Even SVXY is doing great since then (doing $45 to $65, +44% in 2-Years). Now if someone invests in it again, money can again evaporate on any HUGE Volatility spike in the future. Nothing wrong with the product as such, as in normal bull markets, volatility keeps on decaying, helping the -3x ETFs immensely. So nothing wrong with the product, but only for the HIGH-RISK-HIGH-REWARD & informed investors. People can do profit taking at regular intervals, to avoid such "blow-up" pitfalls, & NOT to bet their house on such products (common-sense). 

If the SEC were to protect the investors so much, do BLOCK ALL THE OPTIONS TRADING, and or insure investors from any STOCK LOSSES. 

Else, please let the informed investors enjoy superior returns from ExoticETFs, as it is already a bit difficult to make money in the markets. 

I personally also believe, that some FUND MANAGERs or Associations could be behind such moves, to block the ExoticETFs, as the FUND MANAGERs can never some anywhere near ExoticETF returns in the long run. So rather than helping the clients TIME their investments into such products, some people might resort to getting them blocked. 

I hope the SEC sees though it, and NOT Throw the baby out with the BATHWATER.