March 13, 2020
I urge you to please reconsider the proposed rule #S7-24-15. Individuals should own the right to make financial investment risk decisions under the condition that the asset is not misleading. The proposed changes may result in an adverse impact by steering individual investors to more complex, less transparent investing vehicles to obtain portfolio objectives, or result in a burdensome process that discriminates against persons without the means to participate.
The intention of the proposal is to modernize the regulation of derivatives (such as leveraged ETFs) however I submit that, taking modern technology into consideration, there is a wealth of resources available to advise on the structure, potential benefits, and potential risks associated with trading leveraged ETFs. This allows individual investors to determine their own suitability regarding the trade of leveraged ETFs.