Subject: File Number S7-24-15
From: Bill Porter

Jan. 29, 2020

While protecting investors under the proposed regulations is laudable, I am concerned that additional paperwork burdens might be placed on individual investors who desire to invest in the types of leveraged investments covered by this proposed regulation. My broker/dealer already requires the same investor approvals as required currently for trading options in order to trade in such leveraged investment vehicles, and so long as no additional burdens are imposed on individual investors, I can see no objections to the proposal. However, if the effect of the proposal seriously diminishes the availability of such investment choices, then individual investors will be ill-served. I have a small token investment in an investment fund that specializes in short-selling that I keep as insurance against catastrophic market failure, such as occurred in 2008-2009, when all of my other investments, including supposedly safe fixed income investments, lost money and left me with no financial reserves to take advantage of buying at the bottom of the market. In the event of such market failure in the future, I expect my small token investment in short sales will soar tremendously in value, offering me the opportunity to realize a huge profit that can be reinvested in other opportunities. If purchasing such leveraged investments becomes additionally burdensome for the retail investor, then the opportunity to afford such insurance will become less available. Retail investors who understand the risk should not be subjected to any additional burden.
-          Bill Porter