Subject: File No. S7-24-15
From: James Tom

February 21, 2020

I am an individual investor and have used Leveraged ETFs to
alleviate or minimize the risk of a market crash or correction.

Leveraged ETFs are a powerful investment tool to mitigate RISK and
enhance rates of return. Therefore, Leveraged ETFs should NOT be
restricted from use by knowledgeable investors.

I limit use of leveraged ETF to one of the 3 major stock market indexes,
where my portfolio has diversification and not likely to become bankrupt
as with individual companies like ENRON, LEMAN BROS, etc. during
the market correction of 2008. This is achieved by the allocation of assets
in my portfolio to 50% Cash and 50% in a 2 times leveraged ETF such as
the SP500 (stock symbol SSO). As you can see, my portfolio behaves
like an un-leveraged SP500 index with protection from any downdraft
of a major market correction.

In addition, the higher volatility of leveraged ETFs is a desirable feature
because it provides better than average returns when periodic investments
are made using dollar-cost-averaging. This was pointed out by an
individual investor in a comment to the SEC in January 16, 2016 under
SEC file number S7-24-14 (sn# 35). Below is a link to that SEC file .

There are apparently misunderstandings about leveraged ETF.
Various publications by financial and market analysis are available
on this subject. Below are links to two such articles.

Leveraged ETF Myths Seeking Alpha

Soapbox: Debunking the Myths of Leveraged ETFs ThinkAdvisor