Subject: File No. S7-24-15
From: Lee Tice

May 11, 2020

I am not a professional investor. Leveraged ETFs provide an important benefit to all investors because they allow the investors to effectively be fully invested yet have cash available without using margin loans to capture a sudden increasing equity market.
For example, I want my account to be effectively 100% invested in ETFs. But if the market starts increasing rapidly, I would want to buy more - but cant without a margin loan. Using 2X leveraged ETFs, I can be effectively invested 100% by having 50% in 2X leveraged ETFs and 50% in cash in my account (same gain on investment as 100% non-leveraged ETFs and 0% cash). Using leveraged ETFs allows me to have cash available for increases in equity trends so I dont need to go to margin loans which are expensive and more risky Leveraged ETFs are an important investment tool. They have allowed me to obtain an average 15% gain in my account over the last 11 years
The same benefits apply to inverse leveraged ETFs.