Subject: N/A
From: Roberto Moreno

Mar. 17, 2020

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

Us investors who could benefit from the enhanced return and portfolio protection potential of leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process you are now proposing. I would like the SEC to show why these funds should be treated differently than tens of thousands of other public securities, each with their own characteristics and risks. 
More importantly, the SEC has not shown there is a problem that needs to be solved with respect to leveraged and inverse funds. If it’s not broken, why try such a fix? Requiring us investors to qualify to purchase a security in the public markets would be an unjustified break with how the SEC’s regulation of the sale of securities in the public markets has worked for nearly 90 years. The proposal would be at odds with our long-standing system that gives us investors and our advisers the freedom to make our own investment decisions. Thank you. 

Roberto Moreno