Subject: File No. S7-24-15
From: Barton Hall

February 19, 2020

I am a farmer in my early 70s, and though I remain happily quite active in that profession actuarial tables make it clear that my investment horizon is quite a bit shorter than that available to most people.

My retirement investments are in six figures, and when I finally retire I shall most certainly need to encroach upon capital, preservation of which is therefore important.

Leveraged and inverse funds are consequently an essential component of my planning. More colloquially, they are my "sleep at night" holdings because I no longer have the years available to recover from any serious market drop.

Leveraged and inverse funds are what buffer market swings for me. Broadly speaking, from the last 15 years or so experience, for every 1% the overall markets rise, my holdings rise by about 0.6%. When markets fall by 1% my holdings fall by about 0.4%, often less, depending upon specific sectors and situations.

I hold a lot of low PE stocks and ETFs which in 2019 provided an average dividend return of nearly 5 percent. I'm happy with that, and it is the inverse and leveraged funds which allow me to hold lots of good-dividend equities without fear of taking a monstrous capital haircut which would clobber however many years of retirement I choose to have.

At a very MINIMUM, these inverse and leveraged funds are an important portfolio buffer for anyone within about 15 years of normal retirement.

Please leave the current situation intact, at least for everyone over age 50. We need these funds for our own retirement planning and management.