Subject: File No. S7-24-15 Comment
From: Pablo Dumas

Feb. 02, 2020

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1. Does the exemption to the requirement of a daily, relative VaR test, resulting in 150% or below of its designated reference index, by the fund explicitly stating, among other things, a goal of no more than 300% of returns refer to DAILY returns?
2. As costs, including those relating to the fund's new risk minimization strategies, groups, and related reporting, will undoubtedly, as is supported by numerous historical macroeconomic analyses, be passed onto the consumer - most likely either fully or mostly - what are the methods to further STREAMLINE, DECREASE, or ELIMINATE these requirements for funds?
3. What guaranteed (i.e. not subject to broker judgment) criteria would a retail investor need to meet to attain approval to invest in leveraged/inverse funds AUTOMATICALLY? What are the ways to DECREASE or ELIMINATE the proposed third-party check requirements to increase an investor's freedom and opportunity to invest?
Overall, I wanted to say excellent job with the documentation of this proposal. I just wanted clarification on the above key points as:
1. Given studies across different markets, anything above the 300% daily, leveraged goals seems to be less than optimal in terms of performance. However, 300% daily, leveraged goals in certain markets does prove to be THE OPTIMAL investment vehicle, as is supported by the last decade's top returns, which align with funds with 300% daily, leveraged goals. As several of us have, given the work, education, and freedom related to choosing these investment vehicles, have reaped significant returns with these investment vehicles, which we could not attain effectively via other means, we just want to ensure those returns or the ability to risk for those returns, which benefit us, the broker, and the government, continue being available.
2. Several of us face costs, related to administration and reporting, that add minimal to no value - in that case, detracting value - in our daily work. Given our common feelings towards these costs, typically tied to regulation, we just want to ensure that the funds not only avoid this same burden as a result of the proposal but also avoid passing it onto retail investors like ourselves, which is a losing scenario for everyone.
3. As some of us neither have significant professional - day-to-day job as part of a career, linked to status and compensation - experience, certifications, or even degrees related to finance nor want to divulge additional sensitive data to brokers to invest in leveraged/inverse funds, through which the very same we, as described above, reaped significant returns, we just want to ensure that we will continue to be ABLE, given it is OUR responsibility to research and risk regarding the market and our financial situations - whether we are considered financially experienced by a third party or not - to INVEST, thereby preserving our freedom - and our returns - an element so cherished yet far from guaranteed in our modern world.

Thank you for reading this comment, any future action regarding this comment, and for all that you do daily.