Subject: N/A
From: Ben Parkinson

Mar. 17, 2020

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

To whom it may concern: 

I am very concerned about the proposal for individual investors to have to prove something to the SEC to be able to invest in leveraged and inverse funds. Are you requiring every American who goes to a casino to prove they can afford to lose the money they are risking? Are you going to set up shop at grocery stores to make sure people aren't spending too much on groceries based on their income and expendable cash? This feels like something we would have to deal with living in a communist state like China, but I'm amazed that I'm even having to write this letter to appeal for some sanity here. The investment advice that I have received from the various outlets that I use are very clear that the leverage in these funds works both ways. You can earn more as the fund gains, but you can equally lose more at the same rate as the fund loses. It's a pretty simple concept that doesn't need an MBA to understand. Also, the most you can lose in any leveraged fund investment is 100% of the invested dollars. So if you can't afford to invest in the fund, you won't have the money in the first place to put in it. If people are putting money they "shouldn't" into a leveraged fund, that's no different than any other stock, bond, or precious metal they could invest in. These funds have been a huge blessing to me and my family as we have sought to responsibly build wealth and hedge against potential catastrophic downside. And quite honestly, I'm trying to be polite so you take my comments seriously, but it's amazing to me that the SEC is even considering this for a capitalistic, free market, economy. I would suspect you will find yourself in a class action suit at some point if you move forward with this proposal for playing "big brother" to the American people in a way that no one is asking you to. There are a million riskier and more foolish dangerous things Americans do with their money every day that the government knows it is not their place to police or control. I would highly encourage you to put this proposal aside and move on to something that is actually helpful to fuel the economy. 

Ben Parkinson