Subject: File No. S7-24-15
From: David Lindsey

January 30, 2020

Leveraged funds offer an opportunity for investors to gain enhanced returns and should be broadly available. All investments entail a risk-return tradeoff that investors must manage and anyone is capable of understanding the tradeoff involved in using a leveraged product. Research by Yale economists Ian Ayres and Barry Nalebuff shows that young investors, in particular, gain substantial benefits from the use of leverage early in the lifecycle to boost expected lifetime risk adjusted returns.

Reducing investor freedom serves no purpose and protects no one. The SEC should no more preclude leveraged investments than it should attempt to force older investors to hold high allocations to investment grade bonds.