Subject: File No. S7-24-15
From: Federico A Massini, Massini

March 10, 2020

I find it curious to receive an invitation to protect my "freedom of investment" by Direxion just today after the LI fund I own dropped 41% in one day.
I just today received and read the prospectus of the Brazil 3x Direxion ETF Bull. I now understand how it operates and how risky it has been for the 2 years I owned it.
I thought it followed Brazils index.
Fault on me, and my broker who sold this to me.

Therefore I:

- believe this instrument should be available to the public
- would set some restraints to make sure every investor really knows what (s)hes up to. Something as quick as logging in and signing an "I agree" where, inevitably, you somewhere read "This is based on derivatives and you could lose 80% in two days." I consider myself quite an active investor, but alas I trusted my agent and did not do the due dilligence. I believe this might happen a lot with individual investors. Even with those who try to actively manage their account

Thank you for your consideration