Subject: File No. S7-24-15
From: Paul G Charbonnet, 2663303
Affiliation: Partner, Investors FastTrack

January 13, 2016

The focus on fund holdings misses the point. Every fund is bought with the expectation that management has revealed expected risk return effectively.

Derivative, futures, swaps, and all other type of fund holdings can be used to create very low volatility funds with modest returns. Alternately, they can be used to provide very high volatility funds with very high returns. Also, used to provide every mix in between.

There is nothing inherent in derivatives that make them different from other investments. I have seen Phd academics with brilliant mathematical models involved in funds that offered very poor risk/return. I have seen students living in Europe effectively hedging scholarship dollars with currency funds to ensure that they will be able to pay tuition and living expenses in Euros.

There is no way to regulate the derivative industry effectively except to ensure that regular reports of risk and return are accurate and that they adhere to generally accepted principals. To that end I support the development of reporting criteria, but not specific limitations on derivatives holdings.