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

February 19, 2020

Regarding leveraged funds, I believe they offer a valuable way to have the same exposure to an index like the SP 500, allowing to maintain the balance in cash. We only use leverage in our more aggressive accounts, but the extra cash allows us to have buying power on dips. No doubt they can be misused, but I would argue that buying a bond ETF today has an incredible amount of liquidity risk - most investors don't realize what could happen if the 10-year spiked from its current 1.59% to 2% or 2.25%. There are many risks that should be understood, but they cannot be regulated away. We appreciate the difficult job the SEC faces on many fronts.