Subject: N/A
From: James Sowers
Affiliation:

May. 11, 2020


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

I James Sowers understand the characteristics and risks of L&I Funds as I understand the risks of all stocks and trades that I make. 

The risks and benefits of L&I Funds are so tremendously clear; even for the laymen investor like me! Most L&I products I own are 3x leveraged products which is very understandable and certain, for every one percentage point up or down the sector moves the fund moves up or down about 3 percentage points. This could not be clearer! 

In addition, I understand the risks and benefits of holding these products for a long period of time. There will always be risks in all investing because of the volatility of the market in general but, I understand the higher risk in leveraged products because of the higher volatility and the higher fees but I carefully considered all of these and more before investing. When I first called one of these funds to find out some more information about their companies' products the man on the phone told me about all of the risks stated above. He also strongly recommended that I read the disclosure in the Prospectus of the specific product that I was researching which included a list of some of the risks. 

I currently log into my TD Ameritrade account to monitor my L&I funds every other day so the notion that L&I investors like me do not monitor their investments is irrational. If somehow this injudicious law passes (which will negatively affect my investments), I should automatically qualify to be able to continue to trade L&I Funds under the new moronic law. 

When I invest, I am fully aware of all of the risks. I am more than capable to access risk and I do not need any brokerage or the SEC to tell me if I am “capable" to invest and disqualify me from trading if they decide I am not capable. Basically, I don’t need mommy to decide what I can and can’t invest when I am a grown responsible adult. This fund allows me to trade and gain or lose as if I have three times the money. 

Please do NOT pass the proposed regulations that are contained in SEC Release No. 34-87607 as the regulations will limit clear choices and hurt small investors such as me more than protect us. The SEC should help keep investments honest, but not limit clear choices like this. Of course three potential gains also means potential three times losses. 

Best Regards, 

James Sowers