Subject: File No. S7-24-15
From: Daniel Korth

April 3, 2020

We use a 1.5% leveraged fund about 50% of the calendar year based on an almost 18-year track record. That strategy track record has produced more return then buy and hold on the leveraged fund itself and the index it invests in (SP 500). It has done so with less volatility. This risk management process can only occur if we have access to leveraged products. Do not take that flexibility away and realize that we limit exposure to this strategy in a prudent manner and surround it with many other strategies to midigate risk.