Subject: File No. S7-24-15
From: Douglas Davidson

March 20, 2020

Leveraged funds are an important part of my investment portfolio, I do not want to lose access to them, and I have extensive experience holding them. I believe leveraged funds are simple to understand. They have high fees, they have low dividends, some are better than others at maintaining the leveraged multiple to their benchmark, but they are an important tool for limited use.