Subject: File No. S7-24-15
From: Sari Marks

February 19, 2020

Inhibiting or outlawing an investor's access to leveraged and/or inverse etf funds would deny access to the safest method of participating in bearish or leveraged market activity. Without the availability of such etfs, an investor's recourse would be to buy put options or sell call options, or sell short. These alternatives are far more risky and volatile than the outright purchase of fund etfs. The premium required and the time decay of options makes that investment a loser for the average person 90+% of the time. Selling short is also a tactic for only very experienced investors. Even if a bear etf or leveraged etf investor is wrong in their timing, there is no loss of value due to time decay or required margin or interest payments. The investor can stand pat with their etf for months or years if they feel an eventual turnaround is inevitable...the same as a purchaser of common stock who is a long term growth investor. By eliminating the ability to buy bear or leveraged etfs, the SEC would be removing the most conservative of all the alternatives for bearish or leveraged investing.