Subject: File No. S7-24-15
From: Callum Maclaren

February 20, 2020

Dear Sir/Madam,

I have recently received a notice from my broker Trade Station, that the SEC is proposing new regulations making it more difficult for investors to buy leveraged and inverse exchange traded funds.

I believe this proposal is faulty for several reasons. Firstly, small investors such as myself with limited funds benefit greatly from these products. I have expanded the size of my small account through using UDOW, which is a leveraged ETF that tracks the Dow Jones Industrial Average. This product has worked exceptionally well, has a long track record and I am fully aware of the risks. Secondly, if used sensibly such products can greatly help a small investor reach their investment goals faster. Surely, the SEC should not be trying to hamper the small investor from reaching their financial goals. Thirdly, such a proposed regulation would undoubtedly discriminate against small investors who do not have much capital to invest. The wealthy can and do trade futures or options to leverage gains, the small investor uses leveraged or inverse ETFs which are less risky than futures or options. An novice investor can lose all of his or her capital in future or options, but this is very unlikely in leveraged ETFs because if held long enough the ETFs can recover provided the investor is correct about the overall direction of the market. By making such ETFs difficult to access for the average investor they will probably turn to much riskier investments to try and grow their capital in a world of negative interest rates. Im sure this is not the kind of behavior that the SEC would encourage. Im sure that the SEC would encourage free public markets that allow the investor to use their own intelligence to decide which products meet their own investment needs.