Subject: N/A
From: Dan Magers

Mar. 17, 2020

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

Members of the Commission, 

I trade leveraged and inverse funds. I am quite aware of the risk of beta slip in these funds particularly when held for longer periods of time. I am a private investor and monitor my account positions on a daily basis while managing my own money only. There are several unintended consequences in your proposed regulation changes regarding leveraged and inverse funds. 

1. A broker assessing an investors capability to trade leveraged and inverse funds is a joke and not going to solve any perceived problems. 
2. This will lower participation in a group of investment products that are in the middle of straight stock investments and options and will force more investors up the risk chain into even riskier investments. 
3. With all the red flags and warnings now when a trade is made in these vehicles, the only way an investor would not be aware of the risks associated with them is if they didn’t read the warnings or don’t care. Your proposal is not going to change either of these. 
4. The SEC should focus on the things investors can’t see like insider trading, high frequency market manipulation and outright reporting fraud, not the things we can see like published warnings and risk factor warnings that pop up through the L & I trade process. 

I ask you to drop this proposal to further regulate leveraged and inverse fund trading. 

Thank you, Dan Magers