Subject: File No. S7-24-15
From: Brian Tock

March 10, 2020

I wanted to provide some information as to why I believe that the leveraged ETF funds are helpful for me as an individual investor. I manage a portion of my investments in a brokerage account. I typically invest in biotech companies and mid-cap technology companies. I am a CPA and work for a company that requires I hold any individual stock investment for a minimum of 30 days. The 30 day hold does not apply to investments in ETF or other index/fund investments. I do not have a margin account so I am unable to hedge a position via short positions. I use the leveraged short (Bear) biotech ETF LABU to provide protection/hedge some of my exposure in my individual stock investments when I see heightened market risk due to geopolitical/industry developments. I do this because the 30 day hold period that I am required to follow does not provide me flexibility to exit a position or reduce my exposure in volatile market conditions. I would also like to point out the rational for using a double or triple leveraged ETF as protection/hedge on individual investments. As I mentioned above, I typically invest in biotech and midcap companies which have a high Beta compared to large cap stocks. In percentage terms, if the broad market is down 4% my individual investments could be down 8% to 12%. The double/triple leverage ETF typically provide me risk protection with a Beta similar to my individual stock investments. I understand the risk associated with triple leveraged ETF's and the risk of time duration associated with daily compounded return. I monitor my investments daily and since I do not have a 30 day hold period on the leverage ETF investments I have the flexibility to exit the positions after settlement date. The ability to utilize a leverage ETF provides myself as an individual investor the ability to protect/hedge a portion of my portfolio that otherwise is not available. Restricting or disallowing access to these types of investments will put me at a disadvantage compared to managed funds and other individuals who are not required to hold a security for a minimum of 30 days.