Subject: File No. S7-24-15
From: Puneet Bajaj

February 19, 2020

Dear SEC,

1) Please DO NOT restrict or block investing in the 3x-ETFs for the Informed Investors.

2) Many Legendary Investors, Financial Advisors, do propose that the Markets (or the Top Indices like Dow Jones or SP500) are expected to be HIGHER HIGHER with time. Mr. Warren Buffett quoted in 2017 that Dow can be expected to hit 1 Million (37x) in the next 100 Years (by 2117). It is already up 2.3x since 2017.

3) Same is validated with the Past 100 Year data as well ... If the Dow has risen 350x (350 Times) in the Past 100 Years, it rising 35x in the next 100 years may not be un-achievable. And likewise, that can be projected for the next 10, 20, or 30 years as relevant to our investing timelines (or to save more for our Children).

4) In such a situation, the top of the line 3x ETFs offer GREAT VALUE for the small investors, with Leveraging Compounding effects adding up to a lot over long runs. When SP500 Nasdaq have done 3.3x 4.8x respectively in the past 10 years, the top 3x-ETFs UPRO TQQQ have done a whopping 23x or 61x (23 Times or 61 times) respectively.

A mere $1,000 invested in each would be a whopping $23,000 or $61,000 by now, in 10 Years.

And the UPRO TQQQ have performed EXACTLY as designed, both on the Upside, OR, during the VOLATILE episodes in between.

And in the Long run, such compounding of money is SIMPLY NOT POSSIBLE in the other products, and added benefit, as these ETFs have limited downside risk (similar to buying Options, risking the premium money only).

5) Such INNOVATIVE products do hold a place as small part of one's overall portfolio, AND/OR entire risk capital for the otherwise healthy High Net-worth Individuals.

6) BIG INVESTORS can invest Millions of $$$, and can be OK with Ordinary (Inflation-Beating) returns, but Small Investors with Limited Capital ... DO NEED such Innovative products ... to save a bit for the Retirement.

7) Ample education is available online, INCLUDING the past 10 Year performance data of such products, for the informed investors to design their own responsible strategies. INVESTOR EDUCATION can be further encouraged.

8) Some of the 3x ETFs based on more VOLATILE underlying (Oil, Gold etc.), can include more stringent risk disclosures, or allowed to the more experienced risk tolerant investors.

9) Finally, please do understand that such products do speak to the exceptional US Innovation, and many people from across the Globe, invest in the US markets for such products. Dia-allowing them, or making life difficult for the investors, will reduce the US long term attractiveness for the informed investors.