Subject: File No. S7-24-15
From: Kirt Brown

January 30, 2020

I strongly believe the proposed regulations are:

1. Bad for Investor. If the proposal is adopted, It would take away my benefit from enhanced returns and portfolio protection potential of leveraged and inverse funds. The proposed qualifications are overly burdensome and unnecessary. My brokerage firm could even stop offering theses funds 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. The SEC has failed to show why these funds should be treated differently than the tens of thousands of other publicly traded securities, each with their own characterists and risks.

3. A Dangerous Precedent Requiring me to qualify to purchase a security in the public markets would be an unjustified break with how the SEC's regulation of the sale of securities in the public markets has worked for nearly a century. The proposal is at odds with our long-standing system that gives investors, like myself, the freedom to make my own investment decisions.