Subject: File No. S7-24-15
From: Paul Witmer

March 23, 2020

Leveraged funds are extremely important to me. I have managed them well over several years in a good economy.

I am very capable of understanding leveraged funds...I am a licensed CPA with 35 years of experience and have, in top company finance positions, worked with various brokers negotiating retirement fund investment options for employees.

I strongly believe the long standing free public markets should be preserved. I am not seeing reasonable justification to change this policy.