Subject: File No. S7-24-15
From: Tom Galvin

February 20, 2020

I strongly urge the SEC no not move forward with rule S7-24-15.

I have personally used unlevered inverted ETF since their inception.

They have been a critically important component of my portfolio and wealth management approach. During the great financial crisis they enables me to successfully protect my capital from the markets vicious downturn. Indeed the account for myself and family were only down 10-20% vs -40% for the SPX.

They are also an important tool in my ability to be tax efficient.

Removing access for the individual investor would be a great disservice and make cost effective hedging available to only institutions, hedge funds and the ultra rich.

Unlevered inverted ETFs are more effective and cheaper to use than options and futures.

I grant you that 3x type Funds can be dangerous given the inherent volatility. But the burden should be on the provider to outline the risks and the buyer to understand them before purchasing.

Its in American to deny investors a valuable approach to protecting and preserving wealth.

Happy to present my position verbally if needed.