Subject: File No. S7-24-15
From: Nicholas Carosella

January 30, 2020

I believe many investors do not understand the mechanics of the leveraged funds (in that they expect 2x or 3x the return over a period of time versus the referenced index). Further, leverage amplifies losses. That said, these funds can be a useful means of return enhancement for those who use them as part of a diversified portfolio and understand the mechanics. Perhaps additional disclosure is all that is needed. Inverse funds, especially if unlevered, do provide hedging of certain risks and can be valuable as portfolio protection. As such, as a financial professional, I believe inverse funds are essential for investors and should not be subject to regulation.