Subject: File No. S7-24-15
From: Keith Brookenthal

January 30, 2020

Hi. I am adamantly opposed to Proposed Rule #S7-24-15. I enjoy the ability (and risk) to outperform the market and to hedge my investments. I am aware that leveraged investments can go down as well as up and can do so explosively. We are adults however and capable of making decisions and enjoying or suffering the consequences. I agree entirely with Proshare's sentiments pasted below. Please do not take away investment options from us as if we were children.

Thank you

1. Bad for Investors. If the proposal is adopted, some investors who could benefit from the enhanced return and portfolio protection potential of leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process. Brokerage firms could even stop offering these funds altogether due to the difficulty of implementing the regulations.
2. Unnecessary. The SEC has not shown there is a problem that needs to be solved with respect to leveraged and inverse funds. They fail to show why these funds should be treated differently than tens of thousands of other public securities, each with their own characteristics and risks.
3. A Dangerous Precedent. Requiring you to qualify to purchase a security in the public markets would be an unjustified break with how the SECs regulation of the sale of securities in the public markets has worked for nearly 90 years. The proposal would be at odds with our long-standing system that gives investors and their advisors the freedom to make their own investment decisions.