Subject: File No. S7-24-15
From: Daniel P Smith

January 29, 2020

I support the proposal. I have no connection with the financial industry. I'm a retired software engineer and retail investor, and I participate in an online forum,

To be sure, we get postings from sophisticated investors, who use leveraged ETFs as part of risk parity strategies, with a very full understanding of how they work.

However, we also regularly get postings from investors who think leveraged ETFs are suitable long-term buy-and-hold investments for risk-tolerant retirement savers.

For example, at , a poster asks "if we are betting long term, with the set it and forget it method, why not utilize leveraged ETF's? Such as SSO? I understand the expense rationsic is higher than the target, but the 2X return should easily cancel that out."

Investors are not reading, not understanding, or not believing the caveats stated by ETF providers.

Even Yale professors do not understand these funds. A 2010 book, "Lifecycle Investing," by Ian Ayres and Barry Nalebuff suggest a retirement savings strategy calling for the use of leverage when young. For the purpose of implementing this strategy, chapter 8 explicitly suggests the use of ProFunds Ultra Bull (ULPIX), a 2X leveraged mutual fund, as a long-term buy-and-hold investment. The authors actually discuss the issue of daily rebalancing--and brush it aside as unimportant: "ProFund's rebalancing isn't necessarily good or bad it is just different."