Subject: File No. S7-24-15
From: Douglas Stewart

January 30, 2020

These Exchange Traded Funds assist the small investor in either increasing or hedging the exposure of the portfolio in a more efficient method than futures, or options, or individual stocks when considering the associated risks with these other methods.
Investing possesses risk, but a leveraged exposure to a diversified basket of equities has a uniquely conservative risk profile in comparison with other methods.
Increasing investment tools for the average investor is far more beneficial than reducing the investment options.