Subject: File No. S7-24-15
From: Ron Goff

February 20, 2020

I do make use of inverse funds, and I am fully capable of understanding them and their performance characteristics. I certainly do not want a third party evaluating my capability to do so and potentially preventing me from buying them.
It is notoriously difficult for even the most highly skilled market expert to reliably call market tops. I have yet to find one. So, inverse funds allow me to place a bet that the market has gotten overvalued, and to be able to ride out when the market goes against me. With being long inverse funds, I know what my risk is.
With shorting a market-bullish ETF, my risk is theoretically unlimited.. With buying a put option on the market, I will lose the entire premium if the market continues to rise or even stays flat for the strike period. I really believe that saying that "the market can stay irrational longer than you can stay solvent".
To conclude, I certainly want to keep the long-standing free public markets, where I, as an investor, can buy securities that I choose without additional government-imposed limitations.