Subject: N/A
From: Kodjov Aboni

Mar. 22, 2020

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

To the whom it may concern at the SEC regarding further financial disclosures to access Leverage and Inverse Funds. 

L&I Funds are without doubt riskier investments than non-leverage funds. That being said, the risks involved in these investments are very clear from the Prospectuses of the Funds and from simple common sense. Furthermore one can observe the performance of these funds in times of market stress. 

These funds offer both opportunity and downside. They are in fact no different from most non-leveraged common stocks. leverage can without a doubt accelerate an account portfolio to total loss, but so can multiple other common stocks that are considered blue chip. 

As with any investments, profits will rise and fall. As an investor in leveraged funds in both ETFs and Mutual Funds across a number of strategies, I am well aware of the risk/reward proposition in holding these funds for periods longer than a day or a few days. When these funds no longer fit into my risk profile, I will have no qualm divesting them. 

In the Current market selloff, some of my positions have decline in value significantly, as much as common stock positions which are best in class. My investment accounts are monitored every hour during the trading day. Instead of liquidating my positions in L&I funds, I have steadily increased them. From a risk/rewards perspective, the L&I funds have not looked more attractive as an investment as they are today. 

Good investment management is always required whether one is investing in best-in-class common stocks or in L&I funds. Extremely risk averse people do not invest in L&I funds. Anyone who invests in these funds is clearly aware of the stark and sharp possibility of losses and actively monitor their portfolios. Thus, it is unnecessary to request Brokerage Units to determine who is financially and risk-fit enough to invest in this asset class. I intend to continue to invest in these funds for as long as they exists or create my own strategies, when they no longer do. 

L&I funds provide important hedging function to market participants and incredible opportunities. Access to these funds should not be restricted in any way shape or form. Free and open market access remains an important element in people's ability to control their financial health. Creating additional gateways leads to deadweight loss in the system. 


To free and open market and access ! 

Kodjovi Aboni