Subject: File No. S7-24-15
From: Barry MD

March 19, 2020

I use leveraged ETFs to hedge and reduce risk as well as a tool for protection against catastrophic losses. As such, I strongly hope that they will not be eliminated.

I have a large quantity of physical gold. With less capital, I can use leveraged bearish gold ETFs to hedge against losses when gold is in a sharp decline in value.

After a severe bear market, when losses can be 50% or more in equity portfolios, I can use my limited remaining capital in leveraged ETFs to try and get back to even.

Most investors who use leveraged ETFs are sophisticated enough to know the risks. In fact, ANY equity or commodity investing is risky. Options are especially risky and probably have significantly greater risk compared with leveraged ETFs due to their inherent decay and expiration. Leveraged ETFs have decay also, but not to the same degree as options.

Investors should retain the freedom to use leveraged products and whether they benefit or invest in them to their disadvantage, the option is use them should remain available.