Subject: N/A
From: Michael Gross

Mar. 17, 2020

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

Ian Ayres and Barry Nalebuff of Yale University have demonstrated that leverage can reduce retirement risk very reliably by better diversifying investments temporally. In their book, "Lifecycle Investing", they propose a type of age based fund that initially uses leverage in order to reduce lifetime risk. Regulation that hinders leveraged investing would make it hard to birth such a fund and would block ordinary investors from the potential risk-reducing benefits of leveraged funds. 

Michael Gross