Subject: File No. S7-24-15
From: Frank Schwartz

February 16, 2020

I own a few inverse and leveraged ETFs and have held them for several years now some are doing well (profit) and others not so much. While I understand your responsibility to attempt to protect investors from deceptive and fraudulent practices, that is not what is happening here, at least with the ETFs I own. Before I invest, I always read the prospectus as well as do other research. I consider reading the prospectus to be an investors minimum due diligence responsibility. If an investor cannot understand the prospectus, he should either not invest or seek help some of which is available on the Internet or from the ETF itself. If the investor is unwilling to read the prospectus, he is living dangerously at his own risk you cannot protect investors from their own due diligence failure but, in an attempt to do so, you can unduly burden other investors.

Two investors can, and often do, examine the same financial data and draw different conclusions. Every day while some investors are buying some stocks, ETFs, bonds, etc., others are selling the same securities only time will tell who was right and who was wrong. Investors sometimes make mistakes and the way out is to sell before losses become unbearable (i.e., cut your losses, let your winners run).

At very least, please consider grandfathering investors, such as myself, who are already invested in inverse and leveraged ETFs so we will not now have to jump thru new hoops to keep our investments.