Subject: File No. S7-24-15
From: Craig Israelsen

February 19, 2020

From 1926-2019 large cap U.S. stock (SP 500 Index) has produced positive calendar-year returns 73% of the time. Obviously that means there have been negative annual returns 27% of the time. While it is not possible to accurately anticipate when those negative returns will occur, by eliminating the opportunity to purchase an inverse fund you structurally reduce (if not eliminate) the possibility of investors earning a positive return during market downturns.

The oversight efforts of the S.E.C. would be better spent on broker abuse issues which affect a vastly larger number of investors.

Moreover, by burdening the process of buying a leveraged product you effectively remove the possibility for investors to express a strong commitment to a particular asset class.

The behavioral research is clear: Investment products don't fail investors nearly as often as investors (and advisors) fail the product.

Bernie Madoff was not a leveraged product or an inverse fund.