Subject: File No. S7-24-15
From: Martin Litwack

January 29, 2020

Markets go up. However, markets also go down, such as the 50% loss on the SP from 2007-2009. Investors and traders have the right to participate in both. Using inverse funds can also be used as a hedge, which reduces risk. The current bull market is over 10 years old now, and it is easy to discount the value of inverse funds.
Whether it is eating, trading, or anything else, our choices entail risk. Trading the long side also has risk including, but not limited to: bear markets, leverage, penny stocks, options, futures, etc.
I don't see any evidence for the need to restrict inverse funds, let alone in a burdensome way. If the SEC insists on doing something, why not give Investors documentation detailing their risks in the same way that it is done for options.