Subject: File No. S7-24-15
From: douglas cumming

February 20, 2020

This proposal is absurd. Presumably in a non sep type account I'd still be allowed to short individual securities. That's far more risky than shorting a sector of the market or a particular index such as the NASDAQ, Dow or SP. None of the latter are going to lose 50 or more percent of their value as individual securities can do, and entry and exit into the leveraged etfs is no more difficult than buying individual stocks or etfs. Over the long haul I may well have lost more than I've made on these vehicles but they have helped me sleep at night during times of great tumult in the market when others were losing immense amounts in their accounts managed by others. Someone on FB posted they had lost over 300k in their retirement account during the Jan. 2018 swoon. The leveraged etfs permit this protection to be obtained without allocating a large percentage of total holdings to them. At a minimum, I would urge you to only require the submissions you are contemplating for triple leveraged inverse funds, leaving the 2x funds as they are. (If I understand the proposed rule correctly, it does not apply to short or long instruments that are intended to deliver 2x or 3x on the up or down side) . I have been making my own investment decisions since 2006, which included putting 10% of my holdings into the first inverse etf, DOG, shorting the DJIA, in April 2008. Along with layered stops which resulted in a 70% cash position by early October, these decisions obviously saved me a lot of money, and putting everything back in on Columbus Day got me back in the ballgame, although as we know there were a lot of ups and downs for a while thereafter, during which I continued to use the short etfs. On occasions, I have used upside etfs in certain sectors. I don't need you folks telling me how to make investment decisions. Thank you for your consideration of the forgoing.