Subject: N/A
From: Randall Vodnik

Mar. 18, 2020

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

To the SEC: 

I strongly object to any SEC action that would prevent me from investing in leveraged index ETFs or make such an investment too burdensome. Here are my reasons: 

1) I am an intelligent, thoughtful investor who has been investing since 1981. I do not need the SEC to "protect" me from risk. 
2) I am well aware of the risks associated with leveraged funds. As such, I pay close attention to this investment and, by extension, my other (more traditional) investments. In short, I am more vigilant. 
3) My ProShares leveraged fund is fully transparent as to outlining the inherent risks. Any investor is sufficiently informed to do a risk vs. benefit analysis without SEC interference. 
4) All investments carry risk. By what reasoning does the SEC conclude that a leveraged ETF is riskier than an individual stock? 
5) With all due respect, shouldn't the SEC be spending its resources protecting investors from truly dangerous programs like Ponzi schemes and other Madoff-like offerings? 
6) If this proposal is adopted, and I am forced to sell my position in ProShares SSO, I will incur a substantial capital gains tax. This tax is far worse than a risk. It is a certain financial loss imposed on me by government. Is the SEC going to pay my tax bill? 

I feel very strongly that this proposal would set a dangerous precent and would represent abuse of SEC power and purpose. I will be writing my Congressional representatives to make my position clear. 

Randall Vodnik