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

February 20, 2020

I am an Investment Advisor who utilizes leveraged and inverse funds for clients as a way to "hedge" and protect market downside.

They are simple products to understand and are generally liquid enough to get in and out of quickly and easily. What may be most important to the Securities Exchange Commission is that these products can NEGATE the need for clients to sell their long market securities, thus allowing longer term hold periods as well as providing market support during volatile periods and sharp declines.

I believe these inverse and leveraged products provide a valuable means to protect client portfolios without having to sell securities instead.