Subject: File No. S7-24-15
From: Barry Zasloff

April 7, 2020


I am writing to express my perspective that levered ETFs have served an important role in my investment process and should remain free of further regulations. I have utilized both long and short ETFs and each has played a critical role in my investment strategy and has resulted in a high degree of success. At times I have used short positions as a hedge, so that I would not have to sell out of positions in an otherwise overvalued or stretched market. And at times I have used them to add risk exposure in undervalued market, as I believe exists today. I think it would be a mistake to take this type of optionality away from investors. Thank you for your consideration.