Subject: File No. S7-24-15

February 19, 2020

Putting a limitation on how we use leveraged ETFs to invest on behalf of our clients would be a huge mistake and actually hurt our ability to protect our clients from loss.

By including a small portion (15%) of our clients' portfolios in a triple levered ETF like UPRO or TQQQ we can give our clients 45% exposure to equities through these levered ETFs while keeping a large portion of their portfolios in safe haven assets like cash and U.S. Government Treasuries.

Our current most aggressive allocation includes 40% safe haven assets, 45% individual equities, and 15% triple levered ETFs like UPRO and/or TQQQ. This gives our clients 90% equity exposure, but they still have 40% of their portfolio protected from loss.

To put it another way, without access to these triple levered ETFs we would need to expose 90% of our clients' portfolios to equity risk to get the same return opportunity we give them now with only 60% exposure to equity risk, thereby putting them at higher risk levels.

Regulation without true understanding of how these instruments can be used for the benefit of clients is ill informed and reckless.