Subject: N/A
From: Lim Tian

Mar. 17, 2020

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

I am in great opposition to the newly proposed rule by the SEC. 

The risks of L&I Funds, including the risk associated with 
holding these daily beta products for longer periods of time are always included in a summary prospectus when a trader buys stocks of these funds. 

Personally, I do not believe that any intelligent investor or trader who purchases these products fail to regularly check them due to their inherent nature of high risks. I myself monitor my investments in leveraged funds almost daily through my broker, and take necessary action to manage my portfolio. 

The SEC has already taken tough stances on on margin trading and PDT, therefore severely limiting the amount of leverage that retail traders or investors can borrow. Given that these measures are in place, I do not see the need to further limit the potential growth of retail traders/investors by restricting their purchase of L&I funds. It is my belief that leverage funds level the playing field by allowing traders with less available funds to see a greater return. 

In the case that the SEC goes ahead and enforces the rule, I think that any prior user of L&I Funds should automatically qualify for future trading of L&I Funds. This is easily understandable from how traders who profit from the funds should automatically be classified as being capable of evaluating the risks. Traders who made a loss will likely not trade the funds either way. 

In a nutshell, I strongly believe that most traders/investors of L&I funds are capable of assessing their risk and do actually know what they are buying into. As such, I oppose the enforcement of this newly proposed regulation.