Subject: N/A
From: Michael Ellis

Mar. 17, 2020

Comment on SEC Proposed Rule #S7-24-15: 

To whom it may concern: 
In reference to the proposed rule, it is my opinion the proposal, while well intentioned, imposes overly burdensome and potentially destructive hurdles to providing an open and free market. The proposed changes establish a means to remove or severely restrict a viable strategy that, until fairly recently, only resided among large firms and Wall Street insiders to hedge risks or seek calculated and potentially significant appreciation. The development of low cost inverse and leveraged ETFs represents a large turning point in accessibility to the retail investor of more complex strategies, that before, would only be an option for those with significant assets. 

If significant barriers to utilizing these strategies were to be enacted I believe the industry as a whole would be taking a large step backwards from the more recent leaps forward. 

Michael Ellis