Subject: File No. S7-24-15
From: Sailav Kaji

February 29, 2020

Dear SIr/Madam

I have been using the Direxion and Invesco leveraged ETFs for last five years. It has given me a great toll to invest for short term and sometime time my investment based on market view as well as liquidity management..

I am regular investor who invests USD 3 to 4 k every month. I invest through ETFs . When markets are down i use Levergaed ETFs to buy for say USD 1000 and get exposure of USD 3000. So what i am going to put next month i can put at better timing.

Also i do understand from detailed prospectus the risk of triple exposure nad holding it for longer term view as it may make losses more than it seems so. Also i am well read investor and has detailed study ..
I have net worth of USD 500000 and liquid net worth of USD 250000. I believe i should be allowed to trade those as they are excellent tools to participate time to time as per risk understanding.
I believe if decision is left to brokerage they may not allow me if they feel my net worth is not satisfying or to make me trade in derivates which may increase my risk as derivatives like futures has unlimited risk exposure whereas this leverage ETFs let me take both long and short positions which helps me in hedging also.
Its a tool for well read investor like me to use sophisticated products.
Also i am trading through Interactive brokers. They have made me sign a detailed disclosure regarding complex leveraged ETFs with detailed explanation of the risk associated with it.
I believe as i have been using it for last five years.. on whims and fancy of brokerage my ability to trade though the levergaed ETfs shouldnt not be risked.. also as an existing investor i would not like to loose a proven trading strategy if my broker decides to not offer this ETFs at all