Subject: File No. S7-24-15
From: Jim Milord

Jan. 30, 2020

Why so unwieldy?  Do you not trust my judgement or the judgement of the offerors of these inverse market etf's?  I have been in them for 6 years and am still in a losing position but what happens when we get a crash and I have nothing else to sell?  Are you anticipating a crash and are therefore folding these opportunities for the average guy to protect himself?  Why such a complicated brief, is this a bureaucratic initiative getting paid by the word?  Terrible idea, reduce the costly "protections" from myself. 
James Milord 
Fort Worth TX