Subject: N/A
From: Art Kulaga

Mar. 18, 2020

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

Inverse and leveraged funds are critically important to regular investors in order to protect themselves from extreme volatility and simply adjust beta of their portfolios, without going into marginal account short positions or trading options. ETFs are supposed to democratize stock market access to every person and not just select few wealthy individuals. 

Art Kulaga