Subject: File No. S7-24-15
From: Robert Calhoun

March 12, 2020

As a fiduciary advisor RIA, we need to use leveraged ETFs to quickly, efficiently, and effectively manage portfolio market exposure. We have been using them for over six years and currently use them in 100% of our client portfolios. This allows us to temporarily take advantage of market dislocations, significantly improving our client's long-term returns with only incremental increases in risk. Removing leveraged funds would have an immediate detrimental impact on our clients. We are extremely familiar with the potentially destructive aspects of daily volatility in a structure like leveraged ETFs and manage this risk appropriately. Penalizing accredited institutional investors is unfair and highly unethical.