Subject: N/A
From: Christopher Payton

Mar. 17, 2020

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

respectfully, the proposed restriction on trading leveraged funds seriously disadvantages and discriminated against small investors. It benefits professional and institutional investors and they will charge individual investors fees for services that are not needed. Any investment has risks. No small investor can invest in leveraged funds by accident, especially as brokerage houses display warnings before order confirmation (as they do for stop orders and the like). If leveraged funds are inaccessible the. Small Investors will seek similar performance through a combination of increased allocations (less diversification), options, futures, and short sales. Those instruments are more complex and I submit even more risky, than leveraged funds. Or it it proposed to stop small investors from these instruments as well? The leveraged funds, such as those offered by Dirextion and well documented as to their methodology and application and risks. It should also be considered that leveraged inverse funds are very important vehicles for protective hedges as part of a smaller investor strategy. Thank you. C Payton