Subject: N/A
From: Richard Risner

Mar. 17, 2020

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

Supplementing my prior comments: 
-I have always received documentation including the prospectus and warning notices within 12 hours of purchasing any leveraged ETF. 
-I would not have even known about the existence or chosen to purchase a leveraged ETF if I was not already interested in active trading or looking for that type of financial derivative. 
-I actively monitor my short-term investments each trading day. If I know that I will have a longer period when I cannot check my accounts, I will either check in once or twice a day or I will liquidate my positions if I know that I need to focus on other things. 
-All investing and trading has risks. Different strategies and financial products have different risks. The risks of amplified exposure inherent to leveraged derivative products are related to financial education and the owner's market observation, neither of which can be controlled by a broker--nor should they be. 
-A novice investor who somehow manages to accidentally purchase an inverse ETF will be educated by the experience. A novice investor who takes out a loan to buy three times as much of some other security will be financially crippled by the experience. 
-I do not mind if the ability to trade L&I requires that I accept a few disclosures, as with trading options. I just do not want to be limited in the actual choices that I can make. If you want to protect people who are not educated or sophisticated enough to use an advanced financial derivative, just ask them if they are willing to accept those risks before allowing it rather than preventing them from making choices or educating themselves about different kinds of market strategies.