Subject: File No. S7-24-15
From: Kenneth Kaplan

February 20, 2020

I have used the leveraged and inverse ETFs for years. I cant understand why I would need additional qualifications now. These funds are not as risky as option contracts. They are an important part of the small investors ability to get some leverage and potential use a short where it is otherwise unavailable.

As long as investors understand the risk and make a decision accordingly they should be free to make there own choice. Any investment comes with unknown risks that can happen without warning.