Subject: File No. S7-24-15
From: Calvin Vignes

May 4, 2020

I currently buy and sell leveraged/inverse ETF's as an independent retail investor through my stock broker. I mainly use the ETF's to protect/gain during market turndowns. I also use these ETF's as indicators of the next direction of market movement. I have done these trades for over 10 years. If the rule changes reduce the advantages of these ETF's, I will move money to the commodity markets which can provide similar benefits but are more difficult to manage. I have been a commodity market investor for 20 years.