Subject: File No. S7-24-15
From: David Shen

February 19, 2020

Inverse funds are integral part of hedging portfolio for any prudent investor. After all, you cannot expect market to go up in a straight line fashion, and inverse funds are here to mitigate such decline. The leverage and inverse funds shall be regulated by their inherent leverage and fees, not by eliminating the investor's access to there funds. After all, there are there to protect my portfolio.