Subject: N/A
From: Philip Brachman

Mar. 18, 2020

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

Regarding the SEC proposed rule #S7-24-15, dated November 25, 2019 we would like to register our objections to the proposal. 

We are individual investors who have been managing our investment decisions for over 30 years. Before investing our hard earned savings we extensively researched our investment options with widely available, free investment information. We actively trade leveraged index funds which account for the majority of our capital gains. They are an integral component of our diversified investment portfolio. Before purchasing any fund we carefully explore the potential risks and benefits, and are well aware of the potential losses we could incur. 
Restricting our ability to invest our own capital in this manner would significantly impair our investment opportunities. We do not appreciate a difference in being able to invest in a leveraged index fund or any other potential trade with associated risks, such as purchasing shares in an IPO or any other investment which could result in a capital loss (basically any investment). 

We are concerned that the proposed restrictions would result in additional qualification hurdles for us. It would likely also result in decreased availability of leveraged funds because of increased regulatory burdens on brokerage firms and decreased investor demand with the additional restrictions. 

While we appreciate the fact that there is enhanced risk in leveraged index funds, this is true of any investment today, and we believe it should be the responsibility of the individual who is investing capital to understand these risks and make decisions about investment vehicles accordingly. Individual investors who do not have the knowledge or experience to understand the risks of market uncertainty have available a wide range of investment advisors, from institutional investors to online computerized investment strategies. 

Additional restrictions such as those proposed in this rule are an unreasonable intrusion of regulation over the individual which should not be the expectation of an open, democratic society such as in the United States. 

Philip Brachman