Subject: File No. S7-24-15
From: Gregory Hudson

February 20, 2020

Please do not restrict my ability to buy leveraged ETFs by adding a new qualification process. I use leveraged funds significantly in my investment strategy using a very conservative overall allocation (the majority of my overall exposure is in government bonds), and I've replicated its historical performance for over 30 years as the basis for developing this strategy. If I am restricted from investing in leveraged ETFs, I may turn to futures, an area of the market that is much harder to understand and rife with risk than the leveraged ETF landscape that I can easily understand and model. Thank you.