Subject: File No. S7-24-15
From: Matias Sirena

February 21, 2020

If you are going to ban leveraged and inverse ETFs, then you also need to ban all derivative instruments (options, futures, swaps, etc). This is because you can use these instruments to replicate what the ETFs provide. Not sure whats the fundamental reason for banning these kind of ETFs. If it is to protect investors, then I dont think it will be an effective measure. Again, whoever wants to leverage their investments or bet against a stock (short selling) will find a way to do it with or without ETFs. Ive been responsibly using leveraged ETFs for years now and Im happy to pay for the service they provide.