Subject: N/A
From: Joyce Ludwig

Mar. 17, 2020

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

The advantage of inverse funds for the average investor is we can take advantage of strategies such as shorting while limiting downside risk. As with other funds or stocks, for inverse or leveraged funds the worst possible loss is the initial investment. Restrictions against inverse funds makes no more sense than restrictions about what funds, ETFs, or stocks the average investor can choose--unless the SEC eventually plans to decide who can even invest. There is also a matter of convenience. Investors seeking to short who could not use inverse funds would be driven to actual shorting, which puts a great deal more risk on the average (or any) investor and requires a great deal more experience and constant attention. It is a mistake to think that all investors day trade with inverse/leveraged funds. While these funds indicate they are on a daily basis, many investors following an ongoing trend in some area such as the falling euro hold the fund, and then sell after a period of weeks or months. Day trading is not required. That strategy has worked quite nicely for this average investor, and it would a great loss to lose it. In my opinion, the market and the public are best served when there are many choices rather than a two-tier system that favors some over others. In addition the kinds of information requested is intrusive given there is no greater problem with leveraged/inverse funds than other funds or stocks. There are other areas that go totally unregulated that create massive systemic risk into the market. This is not one of them. 

Joyce Ludwig