Subject: File No. S7-24-15
From: Sean Balog

January 30, 2020

I understand that some investors do not use these funds well and take undue risk through leverage and speculation, but the ability to hedge retirement accounts through inversely correlated funds is immensely helpful when it comes to risk management.

As a portfolio manager, these funds help me to reduce risk to my clients. Denying access to them is unwise and unfair to my clients.