Subject: File No. S7-24-15
From: Dara Grotte

February 6, 2020

One of the first things that hits me when I read through this is that it looks like it is set up to step on the toes of the little guy while those that blew up the system a dozen years ago get a free pass. Why?

I am not necessarily a fan of leveraged funds. But this does not sound like something to rein in the leveraging. It sounds like something that picks and chooses who is allowed to play. And it is not based on investment expertise. It is based on amount of personal wealth.

As for inverse funds, there are not these kinds of regulations on the market going up. Only down. And as a result we keep living in bubble after bubble after bubble. Shorting used to be a way to rein in the excess. Why are you looking to get rid of that, or if you prefer to rein it in? That one does not sound at all healthy or wise to me.

With all due respect, if those of us this rule is looking to protect need the protection, then why are you not looking to rein in those we need protection from rather than stepping on our toes?