Subject: File No. S7-24-15
From: Randall Stone

March 12, 2020

I am an individual investor that makes about a dozen trades a month. I track all my positions EVERY DAY and often intra-day. While I often hold some individual company stocks, I FREQUENTLY use 2x and 3x leveraged ETFs, and infrequently, inverse funds. I have had sufficient experience with leveraged funds to certainly understand both the characteristics, the risks, and the rewards of leveraged funds. Although I understand that they are re-balanced daily, I usually hold a leveraged fund for several days up to a few weeks as long as the market is trending and I am on the right side of the trend.

Regarding the monitoring of my investments, as I mentioned above, I track EVERY position daily. I use the Schwab Streetsmart Edge trading platform, and often am watching 1 and 5 minute charts. I am retired, so make trades throughout the day depending on market action at the time.

Schwab and I are good friends, and I communicate with their customer service group when necessary to either get information, or clarify something. But I cannot imagine how they would make a decision on a customer by customer basis of whether the customer is capable of successfully making money using leveraged and inverse funds. Could I live without access to leveraged and inverse funds? Sure, but I could also live without ETFs and go back to the 1950s and just buy the old 5 letter mutual funds. But that would not be the current market for me, and would obviously change my investing/trading style completely. Neither would I make the returns that I currently enjoy that are provided by the leveraged funds.

The current warnings with EVERY leveraged fund that it is designed for DAILY trading use, not longer term investing, and is not suitable for all investors seems to me to be sufficient. If someone loses money, the answer is "I told you so". But there are risks to ANY ETF, leveraged or not. Or any stock, for that matter. Or any bond, for that matter.

Since I have substantial experience trading leveraged ETFs, I would hope that Schwab brokerage would give me trading authority. Since I have margin, options and futures authorities, I would assume that I would get leveraged ETF authority. But I think the current warnings on every leveraged product on the risks should be enough without the brokerage company having to vet each customer for leveraged ETF trading capability.

Randall W Stone
St. Louis, MO