Subject: N/A
From: Timothy Spooner

Mar. 17, 2020

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

Hello - 

I’m a non-accredited but experienced investor who greatly values the ability to utilize leveraged ETF’s in my portfolio investment strategy. 

Leveraged ETF’s allow me to access a unique combination of diversification and volatility, used in concert with bond ETF’s, in a clearly defined system. This system responds to the natural changes in price to sell at elevated prices and buy at reduced prices, using the bond fund as the cash reservoir, as measured against an established signal line. This system enables me to overcome human tendencies to sell low, and in fact, do the opposite. This system has been extremely successful for me. 

I am very well aware of the risks associated with investing in stocks in general and in leveraged vehicles in particular. It is because of this knowledge and investing competence that I should continue to have access to these investment tools. I greatly value the accessibility and utility of leveraged ETF’s and would be very negatively impacted should access to them be taken away from me. Please ensure this does not happen. 

Thank you. 

Timothy Spooner