Subject: File No. S7-24-15
From: Arvind Chopra

January 30, 2020

Leveraged and Inverse funds/etfs are extremely important to individual investors and their advisors. They provide an efficient mechanism for shorting and leveraging. Without them retail investors would be borrowing on margin to leverage which is the worst form of leveraging. And shorting in individual accounts is also the most inefficient way to achieve short exposure. Other instruments like options are way worse to get leveraged and/or inverse exposure.

Also by reducing access to these products to some sort of "vetted investors", the market place for these products will become less liquid and inefficient.

In short restricting access to leveraged/inverse ETFs will restrict efficient and liquid ways retail investors can achieve such exposure. It will hurt individual investorand put them more at the mercy of larger institutions.