Subject: File No. S7-24-15
From: David Kolstad

March 19, 2020

I would like to suggest that this proposal is quite unneeded, almost a solution in search of a problem. I have been invested in a leveraged fund since 2014 that aims to outperform the market every day and although it is more volatile than many people might like, I am quite comfortable with it. My rationale is very simple: rather than being a noble long term investor, I prefer to recognize that the long term only gets here by going through day 1, day 2, day 3, day 4, and so on. I would much prefer to have someone striving for the best possible performance on each of those days rather than waiting for things to get better again at some indeterminate long term date that someone somehow will decide should be recognized as satisfactory and therefore not unduly risky.
It doesnt require a sophisticated investor to reach this kind of a conclusion, and anyone with enough money to invest in the markets is already made well aware of the fact that things go both up and down. It is not a matter of young innocents being shorn by wolves, so there is no need for this kind of a regulation.