Subject: File No. S7-24-15
From: Herbert Haar

March 10, 2020

It is my understanding that consideration is being given to have brokerage clients requalify to trade leveraged funds. I would like to tell you my experience with leveraged funds and why limiting my access to those funds would be detrimental to my income.
I am 93 years old. I presume that that alone would disqualify me from using leveraged funds.
I have been retired for 30 years. Aside from social security, my sole income has been from capital gains.
In 2019 I had capital gains of $383,142.
So far this year, as of March 9,2020 my account is up 13.1%. SPY is down 14.7%
While I have not calculated it, I am certain that over 90% of my trading is in leveraged ETF's. I generally hold a trade about 1 to 3 weeks.
My point is of course is that I gain substantially from leveraged funds, and denying that source of trades would severely limit my income.