Subject: File No. S7-24-15
From: Stephen Sams

March 12, 2020

Leveraged and inverse ETF's are extremely important to me. I manage my own portfolio, and have for years, using all sorts of types of investments: stocks, bonds, options, futures, as well as these leveraged and inverse funds. I have not found a better way to invest, hedge or speculate than with these funds due to their ease of use, relatively low cost, and ability to help me achieve my financial objectives.

I may be unusual in my experience as an investor, but I absolutely do not believe anyone is incapable of understanding the risks and benefits of these funds by simply researching them appropriately, as should be done with any type of investment. The enforcement of the prudent investor rule is at the individual level, and nowhere else.

Do not take away my freedom of choice to use these funds. I do not believe the financial system is at risk from these products. I am convinced that anyone considering these products faces no more risk from exposure to leverage than with options, which only require the receipt of a disclosure document.

I want my choice to use leveraged and inverse funds to remain open and unhindered.