Subject: N/A
From: Heinrich Erbes

Mar. 17, 2020

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

The proposed rules regarding leveraged and inverse funds are ill advised. They would remove a valuable tool for individual investors. 
Large entities such as brokerage houses and large investors can still "do the same" thing in different ways because they have the resources to do so. The individual investor has to rely on these funds, as their resources are limited. The extra burden of qualifying to purchase or sell these instruments is a BURDEN, and some brokers will simply not allow their client to trade them because of the extra paper work. In short it will be bad for investors. (PS I doubt your evaluation of the Paper work Burden is really accurate. Anything greater than zero should not be permitted. What even happened to Paperwork Reduction?) 

I fully understand how inverse and leverage funds work. Every time I purchase on I get a prospective. The information is all there. Why do I need a "greater level" of protection. Are you planning on the same kind of "protection" for individuals purchase Options? Like making a covered call? 

Is this regulation even necessary? What evil or problem is this supposed to fix or address? DO you have evidence that the is even a problem? A widely distributed problem or a pervasive Problem? If so how come I haven;t heard about it on the News like "Seven on your Side"? Since I haven't heard, I doubt there is a real problem. 

This would be dangerous precedent. It would be different than how the SEC has regulated the purchase and sale of securities for the past 9 decades. It looks like a method of just expanding Big Government, for the sake of Big Government without a clear need. I would not be surprised if you all ready know how many more Bureaucrats you will need to hire for this new regulation. 

heinrich erbes