Subject: N/A
From: Richard Boyer

Mar. 18, 2020

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

I am against the SEC Proposed Rule #S7-24-15. Proposed Rule #S7-24-15 is appropriate for the vast majority of retail investors and probably the vast majority of “investment professionals” (I use the term “investment professionals” loosely). However, it would be inappropriate and punitive to apply this proposed rule to RIA professional like myself who know how to use these investment products properly. In the market sell-off of 2008-2009, when the S&P 500 declined 55%, our clients accounts declined (on average) around 11%. (Our most aggressive accounts declined 18% and our most conservative accounts declined 5%). Why did we fare so well? Because we knew how to judiciously use Pro-shares to hedge the equity portions of our clients’ portfolios, (specifically SDS, 2X the inverse of the S&P 500). Without SDS, our client losses would probably have been double what they experienced. It would be onerous and unfairly punitive to make us get each individual client approved because other idiots don’t know what they are doing or just like to gamble. We don’t use Pro-shares to speculate or gamble. We are NOT trying to guess market direction. We strictly use them to hedge in volatile markets. By the way, we have not purchase SDS now for 9 years. Haven’t had the need to. But when we DO need to use them to hedge, we would like to use them without having to jump through hoops. All three portfolio managers at our firm (Boyer & Corporon Wealth Management) are CFA’s. I am 65 years old and have 39 years experience and know exactly what I am doing. Please exclude RIA’s who own a CFA designation from this requirement. Richard W. Boyer, CFP, CFA 
Chief Executive Office 
Boyer & Corporon Wealth Management 

Richard Boyer