Subject: File No. S7-24-15
From: Alvin Baldemeca

February 23, 2020

For investor that invest in options, leverage funds have less risk than options. If I can trade options then why are leverage funds treated differently. The same risk/reward applies to options and leverage funds and I would argue that leverage funds are less riskier than options. As an example lets take QLD and lets say you bought it at the beginning of the year 2008 that year the it returned -73% from $11 down to $2.78. If you held on to the stock today it would be worth over $140 an over 1200% return from 2008 to 2020.