Subject: N/A
From: Bryce Calton

Mar. 18, 2020

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

I agree with portions of the proposal and disagree with other portions. I agree with a couple of the protections that put upper limits on a VaR calculation and the amount of leverage. These would provide some protection while leaving good opportunity. Also, these changes could be implemented with a calculator. I don't agree with other parts of the proposal, like having to appoint a risk manager, and I don't agree that I should have to be approved to invest in the fund. These funds have higher fees already due to additional requirements and regulations. Adding more regs will increase the cost. Increasing regs will make trading in these more difficult. These investments were the only thing that counter-balanced my paper losses incurred during the COVID bubble-burst. Small investors need access to these investment choices. 

Bryce Calton