Subject: File No. S7-24-15
From: Steven Landis

March 20, 2020

Apparently the SEC, in all its wisdom, is considering significant limitations on access to and use of leveraged mutual funds. This has the potential to restrict a valuable and valid investing technique from both advisers as well as individual investors.

As an adviser, this is particularly distressing since my most valuable strategy year to-date utilizes (long and inverse) leveraged SP 500 and NASDAQ 100 mutual funds. This strategy thrives in times of high volatility and to remove access to leveraged funds would be a loss for clients.

Beyond my own style of investing, leveraged long and inverse mutual funds provide investors of all sorts an opportunity to hedge their existing, long investments versus selling their entire portfolio in order to stabilize their account value.

I consider this a bad, poorly thought-out, emotional consideration by the SEC. Please do not implement this proposal.