Subject: N/A
From: Roger Venable

Mar. 17, 2020

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

Like so many excesses of government, SEC proposed rule #S7-24-15 has not originated from scientific analysis of benefits and harms caused by the matters that it is proposed to regulate. Specifically, the principles of good government require that population studies be done to identify benefits and harms, and following those, statistical studies be completed that quantify both benefits and harms of the matters that are proposed for regulation. Without such studies, the regulating authority has no *real* idea of whether a regulation is needed -- just inadequately informed, and therefore unjustified, opinions. It is important, for the maintenence of a free and just society, that regulatory authorities refrain from preventing behaviors that they have not shown to be generally harmful! 
As a simple example of this, we permit people to drive cars at about age 16, with only minimal qualifications other than age, even though thousands of persons die in auto accidents every year. Society considers the benefits of universally available transportation to far exceed its risks. Those who invest in inverse funds and leveraged funds consider their benefits to exceed their risks. The SEC should have very good reasons -- scientificly supported reasons -- to prevent the public from simple use of these funds. 
As a further example, the SEC requires much paperwork (more than 50 pages at most online brokerages) for the set-up of an IRA account. I have had many friends and acquaintances who have not set up IRA accounts because they consider this paperwork to be egregious. Thus, the SEC has already harmed Americans by over-regulation, while it imagines that it benefits them with these regulations. Where are the population studies and scientific benefit/harm studies on this regulation of IRA's? 
Therefore, proposed rule #S7-24-15 should be rejected at this time. It would be "bad government", were it approved. 

Roger Venable