Subject: N/A
From: Nicholas Difazio

Mar. 18, 2020

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

I am a retail investor who has used leveraged ETF's for the past ten years. I do not trade in these instruments but have purchased them over time, and have continued to hold them. I monitor them daily and evaluate my portfolio vs the major indices on a weekly basis. I have included them initially at about 20% of my overall portfolio, and I only hold ETF's (SSO, QLD) that have very substantial daily transaction volumes. They have increased between 5x and 10x over the past ten years, which will greatly support the financial security of myself and my family in the future. I am glad that I have this investment option, and it would hurt my financial situation if I lost this option. 

I believe that one reason why these ETF's have worked for me so far, is that I don't trade them, they are just a component of my portfolio, and I am only using ETF's leveraged against major indices. They help me diversify away single stock risk, and can be less risky as compared to individual stocks for this reason. Over a long period of time (10 years), the volatility of the S&P index and NASD index are much less, as compared to volatility over a shorter timeframe, reducing the risk of these investments for anyone who can hold them over time (with the exception of a bear market). I know that I cannot hold these ETF's during a bear market, and monitor my positions closely, along with underlying economic data, in an effort to assess the necessary time to begin to trim these holdings. 

My respectful request to the SEC is that investors continue to be given the opportunity to use innovative products like this, in a careful manner, in order to help support their overall financial goals. 

Thank you for your consideration. 

Nicholas Difazio