Subject: File No. S7-24-15
From: Douglas Myers

February 20, 2020

Inverse relationship funds are a perfect way for me to hedge against market volatility and decrease my risk in the portfolio instead of owning bonds. The bond market is under tremendous risk if rates ever decide to turn higher closer to there 30 year average. Under the last three presidents, rates have been held down to the lowest averages in human history and the equity market has been running in bull market for the longest in human history also. These funds are a proven strategy to help portfolios fight against the risks of downward pressure of this terrible market cycle that could take place anyday now. Please consider that if you take these away, investors will have no choice then to just keep the majority if their investment portfolio in money markets.