Subject: File No. S7-24-15
From: Michael Ching

January 30, 2020

I greatly oppose the proposal of the SEC to increase the regulations for the leveraged and inverse funds. There is already sufficient industry warning when we purchase these securities. No investor can claim that they did not know that these are extremely speculative investments. These investments are very successful for their intended purpose. They allow us to control portfolio risks in unique ways that were not available before. We can gradually increase portfolio beta without using all the portfolio assets. These are great investment tools to manage beta.