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

January 30, 2020

I urge you to NOT adopt the new regulations on leveraged and inverse funds.

I use these fund extensively to hedge retirement accounts against market fluctuations. Since we cannot sell short in retirement accounts, there is NO OTHER PRACTICAL WAY to hedge retirement accounts against market fluctuations in periods of high market volatility.

Without access to these funds, you will be greatly increase the market risk in retirement accounts.