Subject: N/A
From: Gregory Chamitoff

Mar. 17, 2020

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

Dear SEC Board, 
I understand that this proposed rule will make it significantly more difficult or impossible for investors to buy leveraged inverse funds. I’m shocked by this proposal and see no sense in it, whatsoever. Personally I have some of my resources managed professionally and some that I manage myself. I use these reverse leveraged ETF funds regularly to protect the value of my accounts against a sudden turn in the market like we are experiencing right now. If it weren’t for these funds, I would have lost more than double what I did lose today - the worst drop in the Dow in history. I did OK because of inverse leveraged ETFs. I still lost money, but I survived. For the individual investor it is very hard to find this sort of protection in any other way. I do some option trading as well, but buying puts would not have protected me as well. I’m fact these ETF’s are far safer to own than puts that expire. Without these ETF’s I would find myself spending a lot more money on puts, which is a riskier proposition. Please do not enact this rule. There’s nothing complicated about these ETFs and the public does not need government oversight of these investments more than any other. 
Thank you for your consideration. 
Greg Chamitoff 

Gregory Chamitoff