October 14, 2020
I am against the proposed changes stipulated in rule #S7-24-15. I am a sophisticated investor who uses both leveraged and non-leveraged SP500 ETFs. As a sophisticated investor I am aware of the risks inherent in using these products. I manage/mitigate my overall risk through the use of Treasury ETFs in conjunction with the SP500 ETFS. The perceived problem the SEC sees in leveraged products is not with their existence but rather that people who are unskilled in their use may be using them. That said I would work to tighten up the "know your client" rules so that individuals who are sophisticated investors truly are and therefore can use these products without limitation. This proof of sophistication should not be overly burdensome.