Subject: N/A
From: Mary Gilligan

Mar. 17, 2020

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

These funds have provided everyday investors as well as professional advisers an opportunity to allocate portfolios diversely and to the current market environment is a perfect example. I have held a Vix fund for years, knowing when the market goes up it will go down, but in situation such as today they would go up and it has. 

This regulation as proposed would be bad for investors, now allowing them access to an asset class that can enhance their long term results for their portfolios 

Why should these funds be treated differently from others? As long as the funds prospectus discloses the risks under current rules they should not be treated differently than any other funds. 

taking these funds away from a large group of investors is unprecedented and takes away investors freedom to choose what is best for their funds. What is the justification for this? 

Mary Gilligan