Subject: N/A
From: Jeffrey Watzman

Mar. 17, 2020

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

Please do not over regulate the inverse leverage funds. These funds are an integral part of a protected portfolio. They are more liquid and less volatile then using options to provide downside protection. Also, as those derivative products may not available in IRA accounts, inverse leverage products are essential! 

jeffrey watzman