Subject: N/A
From: Ross Wagner

Mar. 17, 2020

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

I am a long-time investor and trader and often trade leveraged and inverse funds which allow me to get a position in a particular sector without having to purchase huge amounts of shares in regular funds. Additionally, the ability to purchase an inverse fund to protect my portfolio has been invaluable. In particular, I was in an inverse fund in December 2018, which protected my portfolio and kept me out of the selling fray on December 24 and allowed me to witness the stability of my portfolio and actually purchase some other equities which had crashed and which I felt were good value. To make people "qualify" for these funds takes away the ability of protecting the overall investment and also lowers liquidity. The lower liquidity will further increase the volatility, not only in these instruments, but likely in the overall market as investors find other instruments to take the place of the leveraged and inverse funds. 

Ross Wagner