Subject: File No. S7-24-15
From: R. Diamond

March 25, 2020

Hello --

I am extremely concerned about the prospect of limiting access to leveraged index funds.

I've been investing since the 1980s, and consider them one of most valuable tools I've encountered in 30+ years of investing.

They've been a tremendous stabilizing influence on my portfolio, as they allow me to easily hedge various equity positions, without having to dismantle the entire portfolio -- which took years to accumulate.

Most recently, I've used these funds to mitigate against the recent market fall -- and have been able to sidestep most of that downside. They've been a godsend. I wish they'd been available decades sooner.

Options -- which I'm also qualified to trade -- require reading a disclosure booklet, and answering some questions over the phone, to make sure the investor understands the risks.

If the SEC does deem it necessary to qualify investors similarly for leveraged index funds, there should be a process that's similar, and straightforward.

Institutional investors already have sophisticated means of hedging their portfolios. Individual investors need access to simpler approaches to accomplish the same.

Investors like myself understand and accept the risks.

Thank you.

Ron Diamond