Subject: File No. S7-24-15
From: Rudolph Sacks

January 29, 2020

As a tax lawyer. leveraged and inverse funds play a large role in the investment and tax related planning of many of my individual and family clients. It would undoubtedly be detrimental if access to funds of this type was made unavailable or if access was further limited. Suitability and other safeguards are already in place when opening or maintaining brokerage accounts. Investors should have greater rather than fewer investment choices. Electronic trading, reduced trading costs and friction, and innovation have greatly benefited investors. Leveraged and inverse funds are a product of such forces. Bad actors, fraud and similar matters are where, in my opinion, the SEC should focus its resources rather than impeding positive innovation and change. Thank you.