Subject: File No. S7-24-15
From: Michael Lucas

February 20, 2020

Proposed Rule #S7-24-15 represents a needless over reach on the part of the SEC. Leveraged fund products are valuable tools in the hands of seasoned and professional investors, and can add tremendous value to portfolios. In fact, I used leveraged inverse funds during the crash in 2008, with tremendous results The SEC should, instead, scrap their efforts to reduce the amount of disclosure required for companies coming public and insist on FULL disclosure, thereby safeguarding ALL investors That effort would be far more useful to investors than this rule. It seems that the SEC is, like the Administration, is misdirected in its mission and out of step with the interests of investors.