Subject: File No. S7-24-15
From: Charles Smith

January 30, 2020

1. Bad for Investors. If the proposal is adopted, 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. Not to mention investors qualified to purchase this products would have an extreme advantage and could manipulate the market.
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 a long-standing system that gives investors and their advisors the freedom to invest in various products.