Subject: File No. S7-24-15
From: Robert Merkley

January 29, 2020

By limiting the ability of investors (large and small) to invest in leveraged and/or inverse funds, the SEC will be placing undue restrictions on the free market.

I personally use Leveraged and Inverse funds as a hedge for other investments. They help protect my portfolio. Most of my portfolio consists of very "stable" investments. By using Leveraged funds I was able to produce a market equivalent rate of return over the past few years while having only a fraction of the portfolio "at risk." They have "de-risked" my portfolio which is likely the opposite of what the SEC is concerned they do. Portfolios and their risk/return characteristics must be viewed as a whole. By eliminating or restricting one of the tools I can use, the SEC would actually be causing more risk to my total portfolio, not less.

No one but me should be restricting or determining my personal risk/return tolerance. For me, Leverage and Inverse funds are preferable on the risk/return spectrum to other means of hedging or providing leverage, for example buying or selling options and futures. Their operating expenses are lower than the trading expenses for options and futures and they have no expiration.