Subject: File No. S7-24-15
From: G Walter
Affiliation: Retired

January 30, 2020

As a retired retail investor in the age of reducing regulations, this is truly one of the stupidest rules ever proposed. Jason S. Scott, John G. Watson in their paper from Stanford University, "The Floor-Leverage Rule for Retirement" address the increased efficiency of a portfolio by using leveraged ETFs.

Also, Inverse ETF's are very helpful in reducing downside portfolio volatility. Every retail investor knows there is increased risk and volatility with leverage. We do not need some SEC elitist coming out with a rule making it more difficult for investors to use investments that reduce downside volatility and increase portfolio efficiency.

This rule should be voted down and the SEC idiot that came up with this rule should be fired.