Subject: File No. S7-24-15
From: JOE A

February 19, 2020

The market is at all time highs and had 11 positive consecutive return years. Inverse funds/etfs allow investors to hedge downside risk in their portfolios and potentially offset a market correction. It makes no sense to take away a tool for hedging risk especially at this point in the cycle when theres likely more embedded risk. Inverse etfs allow an average investor a simple way to hedge without the complexities of being on margin or using options strategies.