Subject: File No. S7-24-15
From: Richard Barta

March 12, 2020

If this proposal is adopted, some investors who could benefit from the enhanced return and portfolio protection potential of leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process. Brokerage firms could even stop offering these funds altogether given the difficulty of implementing the regulations.
My wife and I strongly believe this proposal is bad for us as investors, unnecessary, and sets a dangerous precedent. Leveraged and inverse funds are important to us, and they allow us to seek enhanced returns as well as hedge our portfolio. MOST IMPORTANTLY, WE ARE CAPABLE OF UNDERSTANDING LEVERAGED AND INERSE FUNDS, THEIR PERFORMANCE CHARACTERISTICS AND THEIR POTENTIAL RISKS, AND WE DON'T NEED OR WANT A THIRD PARTY EVALUATING OUR ABILITY TO DO SO AND POTENTIALLY PREVENTING US FROM USING THEM. Though probably well intentioned, bureaucratic overreach is a much greater threat to us than leveraged and inverse funds