Subject: N/A
From: Ben Stafford

Mar. 20, 2020

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

Dear SEC: 

I urge you to not invoke additional regulations on brokerage firms regarding leveraged and inverse ETFs. 

Consider that many firms (I know from experience Merrill Edge) already give warnings on EACH trade made for a leverage and inverse ETF of the various risks involved. It shows up in a yellow box prior to each trade whether online or on the mobile device. 

I certainly monitor my investments, particularly when I am holding L&I funds and do not hold them long term. After all, they are meant for short-term strategies. When I hold these funds I always have stop losses or trailing stop losses in place to guard against detrimental volatility. I also will be keeping an eye on the fund multiple times in a day. 

I do not think brokerage firms should have the right to decide if I am qualified to trade these funds? Why wouldn't I be qualified or allowed? Sure, there are risks. But so does virtually ANY equity or holding. At what point is a firm going to be hedging people in to only "safe" investments based on their opinion of what they can understand or what are qualified for? 

I have learned much about trading thanks to the firms who provide L&I funds and benefitted greatly from those funds. Please do not add a rule that would threaten my ability to trade them. 

Thank you, 
Ben Stafford