Subject: File No. S7-24-15
From: Neeraj Kamboj

February 20, 2020

Leveraged and Inverse funds/ETFs are extremely important to individual investors and their advisors. They provide an efficient mechanism for shorting and leveraging. Without them retail investors would be borrowing on margin to leverage which is the worst form of leveraging. And shorting in individual accounts is also the most inefficient way to achieve short exposure. Other instruments like options are way worse to get leveraged and/or inverse exposure.

Also by reducing access to these products to some sort of "vetted investors", the market place for these products will become less liquid and inefficient. The concept of "vetted investors" is stupid anyway.

In short restricting access to leveraged/inverse ETFs will take away efficient and liquid ways retail investors can achieve such exposure. It will hurt individual investors and put them more at the mercy of larger institutions margin and short policies.