Subject: File No. S7-24-15
From: Mordechai Botrashvily

March 12, 2020

Dear Sir/Madam,

I serve as the CEO and CFO of a firm and fully aware of the extended risks of using leveraged or inverse ETF/ETN of any kind.

Currently it is a good opportunity to take advantage of the stock market without exposing directly to futures and so on.
We do monitor our holdings on a daily basis, and also use edging to protect against substantial loss.

It is known that leveraged funds may expose one to even losing the entire investment, especially during the course of time it not monitored on regular basis.

For that reason, and thanks to lessons learned in the past, we take the necessary measures to use these funds for short-term and long-term trading.

Kind Regards,
As for the proposed rule,