Subject: File No. S7-24-15
From: Russ Ferreri

February 19, 2020

Since the financial crisis, the proliferation of leveraged and inverse ETFs has enabled the public investor to perform essential risk management and portfolio hedging tasks. Such tasks were previously difficult to implement and only available to large derivative trading accounts at broker-dealers through an ISDA. Without question, the ability to inexpensively and tactically add such instruments thru an ETF protects and enhances the best interest of the public investor.