Subject: File No. S7-24-15
From: Richard Frank

February 21, 2020

I am a private investor managing my own investing funds. I invest in leveraged funds with a small portion of my portfolio on a regular basis. I believe that instead of the proposed qualification process, a better solution to protect investors would be to limit the amount of their total account balance that can be invested in leveraged funds. For example, an investment limit of 10% with a forced sale if the value goes above 15% would allow private investors to buy these funds without risking the whole of their portfolio. The limit could be scaled according to the leverage.