Subject: File No. S7-24-15
From: Jack Sarkissian

February 28, 2020

Hi Direxion I have been using your LI funds since 2009. Over time I traded executed millions of transactions in your ETFs in an institutional format. I posted this on LinkedIn:

"Direxion sent me this:

https://lnkd.in/eUnruGG

Apparently too many people complained about losses so the regulator decided to put more pressure, and now Direxion is asking for public support. This isn't going to affect me. But I think the regulator has gone too far and want to mention it.

Leveraged and inverse ETFs do come with their own special risks. It hasn't been a secret since certain analysts provided a quantitative description in 2010. That publication slashed the margins of LI ETF arbitrageurs many fold within 2 weeks as public paid attention. LI ETF pricing and risk evaluation may be complex, but it's still MUCH EASIER and MORE TRANSPARENT than for so many blue chip equities or investment grade corporate bonds.

I believe in free markets. After what was already done, people must have a right to be informed or ignorant, responsible or irresponsible."

J.