Subject: N/A
From: Jay Wren

Mar. 18, 2020

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

Please don't limit leveraged index funds. These funds are a great way for me to leverage the market without opening credit lines myself. They are lower risk than many other investment options that I have that are not limited. They are far less risky than penny stocks, for example. 

While I do not day trade my L&I funds, I do watch them daily. I realize that they are re-leveraged daily, and yet I've found use for them beyond that. They have been excellent parts of my balanced portfolio. 

Risk is somewhat subjective. The notion that L&I funds are somewhat more risky than other investments is rather laughable compared to other investments. A leveraged S&P500 fund is made up of mostly-profitable companies. I should be encouraged to buy this. Investing in individual stocks of companies that aren't profitable and often show no means to profitability is far more risky. 

Please do not lock up L&I funds to only accredited investors.