Subject: File No. S7-24-15
From: Michael D Davis, CPA
Affiliation: Certified Public Accountant

June 15, 2016

I will share to you a retail investor point of view about this rule.

I had a very bad experience when Scott-trade and others closed some funds back in 2012, 2013.

They claimed it supposed to be "an orderly and efficient process".

The result was, the to-be closed ETFs crashed up to 15% on the news, and then more. The non-professional investors were the ones who suffered the most. Since most of us are not actively managing our portfolios, we were the last to run for the exit.

There is not an official list containing which exact products will be affected by the rule. Small investors community is in the dark, at this very moment anyone could be doing their worst investment decision ever. Sadly, the SEC is facilitating this, by not having full disclosure of which instruments exactly are to be banished if the rule is approved.

If protecting the investor is the goal, why not do it in the same way they handle options trading at brokerages, based on risk tolerance and profile?

I cannot grasp at the idea, in a problem this complex, the SEC is going for the "one size fits all" approach.

The rule fails to describe an implementation approach, which ensures it does not adversely affect investors, if that is even possible.

I hope you pay attention to this real-life experience.