Subject: N/A
From: James Rakowski

Mar. 18, 2020

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

Dear Sir or Madame, 

I just read Tradestation's notice about the SEC getting involved to determine who should and should not trade triple leveraged ETF's and inverse ETF's. 

This scares me to death because these are the only markets that I trade and I have been doing so for approximately 10 years. These markets move strongly and market movement equates to profits in the way I trade them. I might stop trading if I am not allowed to trade these wonderful markets. 

I highly subscribe to the premise that we all are responsible for our own market losses and we all must find a method that suites us. I have lost a great deal of money in the past trading markets that were not leveraged, so in my case you have a negative correlation between losses and triple leverage ETF's. These losses were a learning experience for me and motivated me to improve my methods, in fact, I know very well known traders who have at some point taken serious losses, and they also corrected and went on to be successful. 

So please do not put yourself in the position of a regulatory agency deciding for me if I am competent or not competent to trade certain markets. I am a big boy and I can figure things out for myself. 

When it comes to inverse markets, I can demonstrate to you that inclusion of these ETF's into a trading plan will significantly lower drawdowns (losses), so these ETF's are likewise very important to rule-based, risk managed portfolios. Therefore they are also important to my trading plan. 

James Rakowski