Subject: File No. S7-24-15

February 20, 2020

As an individual investor who has made my own investment decisions for many years, I don't feel the need to "prove" or "qualify" that I am capable of making a decision whether or not to invest in leveraged or inverse securities.

I know and understand how the portfolios are constructed and the inherent risks that go along with them. The disclosure requirements in place put the information in my hands.

Because I am prudent in the management of my portfolio I have set a limit that I will allocate to leveraged and/or inverse securities that is acceptable to me.

I don't need a third party assessing my ability to use these vehicles. Again, I have been given the disclosures, I understand the risk, as a free market participant it is up to me to determine if I choose to use these vehicles.