Subject: N/A
From: George Galanis

Mar. 18, 2020

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

Reverse splits should be limited on these kinds of L&I Funds. There is certainly a methodology of taking people's money by doing so since this is not an instrument that everyone understands (as you have greatly appreciated). I don't think permission would be needed but certainly some type of control on reverse splits since an investor expects for an ETF like this to act somewhat like a stock but could be hammered pretty bad and lose a lot of money with reverse splits. There should a limit on how many reverse splits can take place in a certain period of time.