Subject: File No. S7-24-15
From: Ryan Pinju

February 19, 2020

I am an accredited investor with 15 years of trading experience and a master's in finance. I use an individual and Roth IRA account to manage several million dollars for myself. I'm very aware of the risks associated with levered and inverse ETF's. I understand the math and the black swan risks extremely well. I invest in these products at my own discretion with a full understanding of the risks.

I understand's the government's desire to protect some investors from products that they don't fully understand. However, I don't think its appropriate to limit or handicap qualified/accredited investors in participating in these types of instruments.

Preventing me from investing in these would negatively impact my trading strategy and would severely hamper my long term investment goals.