Subject: N/A
From: Joseph Koch

Mar. 18, 2020

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

I am writing to voice my strong objection to Proposed Rule #S7-24-15. As a small investor myself, the ability to invest in leveraged or inverse funds is an important option that every investor, and especially the small investor, should have available to them. 
First, small investors sold not be put at an unfair dis-advantage to large institutional investors by restricting or limiting their investment choices. This goes against the basic concept that all investors should be able to participate in an investment market that has fair and has equal opportunities for everyone. 

Second,leveraged and/or inverse funds are not difficult for the average and active small investor to understand and determine if they are suitable for their investment goals, risk level and strategies. The average small investor is not only far better educated than before, but they have a wealth of education and information available to help them better understand these type of investments, and if they are suitable for their investment goals. At most, a VERY brief (less than 1/4 page) written warning that these investments are not suitable for all investors and MAY carry unique investment risks that each investor must click and acknowledge should be the ONLY added small step that small investors must take before investing in these investments. Honestly, I find it insulting that anyone, especially a government entity, does not think that small investors such as myself are not capable of understanding or properly using these types of investments. 
Leveraged and inverse funds allow the small investor access to strategies to limit their losses or potential risk or increase their potential profits during periods of long term market downturns or other world events. The virus outbreak in China is a classic example of where world events could have longer term negative impact on investments,. Inverse funds would allow the small investor the opportunity to evaluate these events, how they might effect their investment returns and evaluate inverse funds as a reasonable investment opportunity to preserve their profits or even increase them over time. 
As a small investor who has used inverse and leveraged funds very effectively on numerous occasions, I strongly encourage the SEC to REJECT Proposed Rule #S7-24-15 as being unfair and unnecessary. 

Joseph Koch