Subject: File No. S7-24-15
From: Walt Clark

January 29, 2020

I have used leveraged and inverse funds for many years. They can be an important tool in portfolio construction and restricting access to these products for some investors may create an non-level playing field where some investors may be denied the ability to use products that they would otherwise prefer to use and benefit from. Those investors who are denied access to certain leveraged or inverse products could be placed at a disadvantage compared to other investors who have free access to those products. Or, even worse, those investors who are denied access to leveraged and inverse products could end up making even worse investment choices in an attempt to protect their portfolios. Limiting the tools available to some investors in an attempt to protect them may actually end up harming those very investors. Everyone should have the same choices and opportunities in the market. As it has always been, it should be up to the individual to understand and be responsible for their own personal risk/reward strategy. I strongly disagree with the part of this proposal that could restrict access to leveraged or inverse products to only certain investors.