Subject: File No. S7-24-15
From: Darryl Hall

February 19, 2020

Don't do it Individual investors need ways to invest or trade against bear market scenarios. Inverse ETFs offer a more diversified way to do that than shorting stock or buying put options. Doing away with inverse ETFs push such investors towards those more risky options. Why would the SEC selectively focus on just this one type of trading? Investors should prefer more ways to deal with bear market scenarios than less.

Similarly, some investors want bullish leverage without taking the level of risk associated with buying call options or futures. Leveraged ETFs offer a diversified way to trade with some leverage without having to go for exposure to more risky options. Taking away leveraged ETFs push those investors towards the greater risk of those other options.

ETFs are much easier to understand and use than more complicated options and margin-required shorting scenarios. And If I'm nervous about a potential market fall, they offer an insurance-like hedge so that I don't have to entirely flee to cash until markets stabilize again.

Let individual investors traders make their own decisions on whether leveraged and inverse ETFs are right for them. The Government shouldn't be making such decisions for them... nor picking choosing what types of leverage and bear trades are OK. Those who use such tools are exposed to enough knowledge to grasp what they are and how they work... certainly at least as much as those who use options futures for leverage and put options or shorting for bearish trades.