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James Johnson Comment On Regulatory Notice 22-08

I have been using leveraged and inverse ETFs with great success for 12 years, with proof of performance results far greater than S&P 500. I have an MBA from Tulane, but my trading education began by studying with Steve Lescarbeau, featured in Market Wizards by Jack Schwager. My experience and methods of analysis of selecting appropriate funds are far beyond the many authors of articles about leveraged funds, the vast majority panning them, and viewing them through an ultra short term prism. To be blunt, they have missed the boat.