Subject: File No. S7-24-15
From: James Lubin

January 30, 2020

I am opposed to this Rule change for the following reasons:

1. Bad for Investors - Overly burdensome qualification process will prevent their use by investors
2. The Rule is unnecessary, the SEC has not shown a problem with the use of levered or inverse etfs.
3. This Rule change would set a dangerous precedent, it prevents investors from making their own decisions.