Subject: File No. S7-24-15
From: Douglas Burtner

February 20, 2020

I use leveraged and inverse funds to help me trade ideas or trends that would be difficult to otherwise. Often the margin requirements for leveraged and inverse funds are higher than other ETFs, so it evens out to some degree. If inverse funds were not available to me it would require a lot more effort on my part to trade certain ideas or trends.
I understand how options work and that there is often a time decay component to leveraged and inverse funds
If I were no longer able to trade leveraged or inverse funds it would make it harder to hedge and diversify my portfolio, increasing risk