Subject: N/A
From: Herbert Brust

Mar. 18, 2020

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

1. Bad for Investors. If the proposal is adopted, some investors who could benefit from the enhanced return and portfolio protection potential or leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process. Brokerage firms could even stop offering these funds altogether due to the difficulty of implementing the regulations. 2. Unnecessary. The SEC has not shown there is a problem that needs to be solved with respect to leveraged and inverse funds. They fail to show why these funds should be treated differently than tens of thousands of other public securities, each with their own characteristics and risks. 3. A dangerous Precedent. Requiring you to qualify to purchase a security in the public markets would be an unjust break with how the SEC's regulation of the sale if securities in the public markets has worked for nearly 90 years. The proposal would be at odds with our long-standing system that gives investors and their advisors the freedom to make their own investment decisions. 

Herbert Brust