Subject: N/A
From: Cheung Lun

Mar. 17, 2020

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

I am writing to express my concern about the new proposal of leveraged and inverse funds. I am now investing on those fund and I think is should be a bad rule for investors 

1. leveraged and inverse fund is import for me, because I want to use low cost to leverage my position, and I got a great return in the past. Also I can protect my position by different asset (eg I use treasury etf, inverse etf and stock option) , which can reduce my risk efficiently. 

2. Margin leveraged investment and other leveraged investment(eg stock option, futures etc) are risky than those etf. If you apply the new rule to those etf, should it to apply on all margin accounts ( which may loss more than your total investment amount)? 

3. Investor should know the leveraged and inverse etf for their own, it is not reasonable to need a third party preventing our investment. 

4. I am a HK investor, and we also have those leveraged and inverse funds in HK. I think the new rule is going backward in US exchange! 
5. It is more difficult for our foreign investors if we need to provide such information 


Cheung Lun