Subject: N/A
From: Daniel Gierl

Mar. 18, 2020

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

I broadly understand the SEC's concerns about leveraged and inverse funds. I strongly believe that the correct response, if the SEC decides to regulate such instruments, would be to regulate the design and implementation of the instruments themselves, rather than limiting investors' access to them. 

I expect that limiting access to the markets created by these funds will principally serve to create arbitrage opportunities that can only be exploited by the privileged investors who can meet the SEC's arbitrary constraints. 

It's important to me, not only from the perspective of the function of the overall system, but also personally as an individual investor, to have access to these specialized funds. 

Daniel Gierl