Subject: File No. S7-24-15
From: Simon Tate
Affiliate: Support Group Ltd.

December 15, 2015

Dear Sir,

Please find attached my concerns/comments regarding the proposed regulatory changes to leveraged ETFs as proposed above. I initially sent this e-mail to Direxion Investments. However I would also like to lodge these concerns/comments with the SEC itself. Please accept this forwarded e-mail as such.

Yours sincerely, Simon Tate.


---------- Forwarded message ----------
From: Simon Tate
Date: 14 December 2015 at 13:22
Subject: SEC Leveraged ETF Proposed Cnanges

Dear Sir,

I am a UK investor who manages his own SIPP (pension) portfolio. In the last 4 to 6 weeks I have been building up positions in UWTI, UGAZ, JPNL,RUSL,INDL,BRZU,YINN,TMV,EDC,EURL,NUGT.
In total  my portfolio amounts to around £0.6M of which approximately 90 to 95% is invested in UK and US Blue Chip stocks and bonds AND the rest (around 7%) in the leveraged products above. I am a professional investor (ex-investment banker) and it is my intention to maintain these leveraged positions as a long term hold (5 yrs). Consequently I have not been too bothered about any short term trading profits/losses as my horizon is more long term . However when I read that the SEC is considering imposing a cap on leveraged ETF products I was extremely concerned that I might end up in a position of having short term trading losses crystalized by some new rules. I was partly relieved that in the proposal document the SEC mentioned "grandfathering" funds already established before the new proposed rules - however this does not appear to be a "done" deal yet and I am not sure how the funds would be managed on an ongoing basis.

AS far as the SEC is concerned , please feel free to use this e-mail in any case you might decide to put before the SEC. I appreciate that the SEC has now proposed a 90 day consultation period and that you are likely to be putting your concerns/case to the SEC. Secondly if you think it is worth it I would be very happy to send this e-mail directly to the SEC if it would help OR if I am entitled to. Please let me know !

Finally please could you let me know the proposed Distribution schedules on the ETF's above.

Your's sincerely, 

Simon Tate

The Support Group Ltd
T : 07916284556

The Support Group Ltd, 169 New Kings Road, London, SW6 4SN
Registered in United Kingdom. Company number: 6480519