Subject: File No. S7-24-15
From: Allen Montgomery

January 30, 2020

Leveraged ETFs do not expose the investor to more risk than an individual stock.
Investors with IRAs or other qualified plans cannot use margin or otherwise borrow, which makes an IRA a disadvantage to portfolios outside qualified retirement accounts. Leveraged ETFs used with prudence and caution can be an effective tool for enhancing wealth building.