Subject: File No. S7-24-15
From: Matthew Crouse, Crouse
Affiliation: Westminster College

March 22, 2020

In a follow-up to my prior comment, I will point out that several leveraged investment products are liquidating due to the current crisis and more will follow. One fund even announced an intra-day NAV of 0. These are the risks I were warning about in my research paper "Leveraged Investment Products: Monthly Rebalancing Boosts Performance, but Tail Risk Looms"

Here are links to the news items regarding liquidations and zero NAV: