Subject: N/A
From: Jeffrey Spencer

Mar. 18, 2020

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

As a long time investor of Mutual Funds, ETFs, and individual stocks, I think your proposal to limit people’s ability to invest in leveraged funds is wrong and doesn’t represent the free market capitalism that makes this country the best economic engine of growth in the world. As long as a person knows that their investments can fluctuate, I do not see an issue. Leveraged funds are generally more diversified than a hand full of penny stocks. 

Think of the person with limited funds, or one that is on a fixed income but has some investable funds. A retired couple if you will. This couple may want to keep the majority of their money in fixed income assets that provide them with a good current income, but they don’t need to lose future income to inflation. They need a way to keep up without risking their current earnings. They could put 20 percent in a leveraged fund and gain enough exposure to equities to outpace inflation while keeping 80 percent of their assets in safe fixed income funds or bonds. This would provide a similar return that a 40 to 60 percent exposure to the market would without risking their current income. I believe there is a place in the average person’s portfolio for leveraged funds. 

I also believe most people understand the risk of investing and make sound decisions without being blocked by government regulations. 

Jeffrey Spencer