Subject: File No. S7-24-15
From: James Wang

February 19, 2020

I strongly oppose the Proposed Rule. Leveraged ETFs can be held long term IF they are used as part of a risk parity framework and balanced regularly. Historical backtesting has shown that a 40/60 mix of 3x leveraged SP 500 and Long Term Treasuries rebalanced quarterly actually delivers twice the CAGR of the SP 500 at similar volatility.