Subject: File No. S7-24-15
From: Ami Hubbard

January 30, 2020

Comment on SEC Proposed Rule #S7-24-15

Why are you trying to fix what does not appear to be broken? Leveraged and inverse funds have been created and utilized by self-aware investors for almost 14 years. Your proposed new due diligence requirements are untimely, most unnecessary and set a dangerous precedent of government overregulation of successful financial products.

Leveraged and inverse funds are important to me and my family. They allow us to seek enhanced returns and help us protect our varied investment portfolios.

We are capable of understanding leveraged and inverse funds, their risks and performance characteristics. We do not, nor should any self-directed or advised investors, need a third party evaluating our capability to do so and potentially preventing us from buying them.

We also want to preserve the long-standing free public markets where investors and their advisors have the freedom to buy public securities without additional government-imposed limitations on investor choice.


Ami Hubbard