Subject: N/A
From: Rich Lowrie

Mar. 17, 2020

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

The proposed rule is terrible. I use inverse funds as part of a disciplined, repeatable process. The fact that my clients have positive returns during this 20% market sell off, thanks to the proper use of inverse funds, speaks volumes to their value if used properly. How do I protect clients if you take them away? I guess I could short, but it's not permissible in IRA accounts. If someone out there is using them improperly, aren't there already rules against improper use of financial instruments? Why is it a good solution to punish people who use them responsibly? You have my email, I am happy to discuss this further. 
Rich Lowrie