Subject: File No. S7-24-15
From: Robert Shapiro

January 29, 2020

I feel that your proposed rule, while it might seem in good intentions, it will only hurt us, the retail investor. Inverse leveraged ETFs DO NOT put us in harm's way. Just like ANY stock, yes, you can lose all of your investment funds. However, you aren't leveraged in a way that will put you in a deficit if the position moves against you ( unlike futures or currencies ), so you don't have to worry about catastrophic losses, or potential spillover/contagion into yours or other people's assets.

I strongly recommend you refrain from passing this rule. All money put into the stock market is AT RISK no matter what you do. Why wouldn't you give us the equal ability to hedge our positive stock positions with an instrument that's easy and liquid for us, that moves inverse to the markets? It's no different than buying Put options, but you don't have to worry about the loss of value due to time decay.