Subject: File No. S7-24-15
From: Dan James

February 20, 2020

Your consideration of changing the ease in which investors can trade leveraged and inverse funds will negatively impact my ability to trade . These funds are a useful and safe way to buy or sell securities. Limiting investors use of these instruments would be a restriction of free trade. These instruments are much safer than the alternative, futures. With futures you really do not own the underlying security because of the very high leveraged loan arrangement that can easily cause a forced liquidation and renewal at expiration date. The funds you are considering restricting are a safe alternative. As a physical metals trader buying and selling these funds are necessary to hedge my physical trading with out the risk of futures. I may not have enough funds left after my physical metals buying to properly hedge with a non leveraged fund such as gld or slv. The 2 and 3 times leverage offered by the funds are necessary for me with out the risk of futures. I also find stock market funds useful in the same way . I trade tqqq and sqqq as well.