Subject: File No. S7-24-15
From: Andrew Heiden

January 29, 2020

Any restrictions that would make investing in leveraged ETFs especially difficult for regular investors are unnecessary. Restrictions would hurt regular investors by limiting easy, cost effective ways to utilize leverage. A rule like this would effectively push a good portion of leveraged ETF investors toward the riskier and more complex alternatives like options or direct margin borrowing.

I'm not sure what is driving this rule, but it would have the perverse effect of limiting the options of investors with more modest asset levels while leaving more aggressive or creative investment options to the hedge funds and wealthy investors with the time and resources to deal with the complexity.