Subject: N/A
From: Douglas Dreher

Mar. 17, 2020

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

I run a systematic quarterly rebalancing plan that is partly powered by leveraged ETFs. I know what I am doing, have been doing this for several years, and did not panic in December 2018. The proper use of these leveraged products is a key part of my financial plan. 

These funds are important to me. They improve my performance over the long term. I am not engaged in reckless trading, I understand the effect of daily magnification of an index’s price movement, and I use this magnification to my advantage. 

I do not want a third party evaluating my capability of managing these funds, and certainly do not want one preventing me from buying them. 

If leveraged funds are restricted to accredited or wealthy investors only, the wealth gap in the country will increase as the rich get richer in sophisticated products while everybody else languishes in plain old index funds. 

Please keep leveraged funds available to all investors. 

Douglas Dreher