Subject: File No. S7-24-15
From: Brian Winchester

February 19, 2020

I use a systematic quarterly rebalancing plan that utilizes leveraged ETFs. I know what I am doing and am fully aware of potential risks involved in their use. The proper use of these leveraged products is a key part of my financial plan.

These funds are important to me. They improve my performance over the long term. I am not engaged in reckless trading, and understand the effect of daily magnification of an indexs price movement. I use this magnification to my advantage.

I do not want a third party evaluating my capability of managing these funds, and certainly do not want one preventing me from buying them. This is unwarranted government intrusion.

If leveraged funds are restricted to accredited or wealthy investors only, the wealth gap will increase as the rich get richer in sophisticated products while everybody else languishes in plain index funds.

Requiring that investors prove themselves to be accredited before receiving the right to buy and sell leveraged funds is not the correct way to ensure a greater level of safety to investors using these products. Please keep leveraged funds available to all investors.