Subject: File No. S7-24-15
From: Steve Luhmann

February 21, 2020

Dear SEC members, Leveraged and inverse funds are important to me therefore I am opposed to the proposed rule #S7-24-15 for the following reasons. First, leveraged and inverse funds are important to me because they help me receive higher returns on my investment and help me protect my portfolios. Second, I am very capable of understanding leveraged and inverse funds and their characteristics. The prospectus clearly lists their performance characteristics, and I do not want an outside party deciding my capabilities and potentially preventing me from using them to achieve my financial goals. I have used them since 2009 and they have been a tremendous asset to my investment strategy. In fact, I believe leveraged ETFs are safer than investing in stocks because they are diversified yet I can still achieve returns that high beta stocks offer. When I invested in just stocks I would frequently lose money because of company risk, such as a CEO leaving the company or poor company performance. Finally, I want to preserve the free public markets investors and advisors have had so long and have the freedom to buy public securities without government intervention on investors ability to chose. Regards, Steve Luhmann