Subject: File No. S7-24-15
From: Irwin Roth

February 19, 2020

Dear Sirs/Ladies,

I am strongly against the proposal to place restrictions on who may use leveraged and inverse funds. I have used these funds regularly for the past 10 years and I find them an essential part of my portfolio. I am fully aware of the risks involved with these funds and I believe that everyone who uses them knows the risks. The funds issue detailed prospectuses that fully advise of their risks and advantages. There is no "evil" in these funds which needs to be remedied.

As they are now constituted, these funds are extremely liquid, but putting restrictions on who may use these funds will severely decrease their liquidity and their usefulness. I urge you to follow the dictates of the precept "If it ain't broke, don't fix it". Nobody says these funds are "broke", so I don't understand your rationale for trying to limit them.

Finally, I think that focusing on this subject is frankly a waste of your time. I would suggest instead that you investigate the short-sellers that wreak havoc on small publicly held corporations. I have held stock in one such corporation for 5 years now and every time good news was reported by the corporation, the shorts bid the price down by 50 to 75 %, and they ruin stocks that way. From what I have been told, I understand that that kind of stock manipulation is rampant within the industry. Why don't you focus on that problem? I would be glad to advise you further in that regard if you wish. Dealing with the stock manipulation would truly be doing something useful for investors, but focusing on leveraged ETF's is, in my opinion, not only truly a waste of your time, but would do great harm to the investors that use and rely on these funds.


Irwin Roth