Subject: N/A
From: Alex Wernberg

Mar. 18, 2020

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

I am a retiree who has beern investing in the stock market for over fourty years. I have found the use of double and triple leveraged broad market index ETFs to be extremely valuble in controlling the risk of my portfolio. For instance, my use of leveraged funds such as UPRO allows me to invest only 30% of my portfolio in UPRO, with the remainder in cash, and still have close to full market exposure with, in my opinion much less risk. Having 70% cash in my portfolio makes me less prone to reacting to market volitility than if I had a 100% position in an unleveraged SPX based ETF. The use of leveraged ETFs is, in my opinion, vastly superior than to using "Margin" - there is not the threat of a margin "call" or payments of high margin interest. It does not make sense to me to allow investors to use margin while limiting their use of a vastlysuperior product such as broad market leveraged ETFs. ETNs are another matter and in my opinion are much riskier and hence I avoid them. If barriers to the use of broad market ETFs are put in place, I think that it would be very negative for many small individual investors like myself, who routinely use these funds to control the volatility of their portfolios. I am requesting that the SEC continues to allow the use of leveraged ETFs without placing new restrictions on the ability of individuals to utilize their benefits. 

Alex Wernberg