February 19, 2020
I have used leveraged and inverse funds for the last 25 years or so, primarily as a partial hedge or balance against primary positions. For example, since rising interest rates negatively impact the value of a traditional bond portfolio, I will hedge a $100,000 bond portfolio with a $10,000 rising rates inverse fund, to provide me with a modicum of protection against an increase in interest rates. If anything, the proposed rule (#S7-24-15) will INCREASE my portfolio risk, because it will reduce my ability to utilize this particular strategy. I see no reason for the rule, and I urge that it be rejected. THANK YOU for considering my input.