Subject: File No. S7-24-15
From: Vernon Brown

April 17, 2020

I am a 71 year old retiree with an MBA from Harvard Business School. I have successfully used inverse funds over the last three years to protect my retirement portfolio from market swings and to allow participation in the equity markets while lowering the beta of my portfolio. Inverse funds are liquid and allow portfolio hedging when markets move violently, as they have in recent times. Because of this market tool, my retirement portfolio was preserved in the recent market reversal, without having to dump the portfolio onto a market in freefall. Please do not eliminate this valuable tool from the investor's market options.