Subject: File No. S7-24-15
From: William Gotchey

February 20, 2020

Without inverse funds, people who have Roth IRA's and other IRA's could not make money in a bear market. The next bear market is unknown but it will happen. I was able to make some money during the Great Recession using inverse funds. In my 401-K I had no way to short so I went into cash. I am very experencied using thses wonderful investments. However, people new to inverse ETF's coud trade using paper money, not real money for a month to get the feel of this TD Ameritrade and many other brokers have such account that act just like the real market. It would hurt investers not to be able to protect themselves and not much of a chance to make money in a bear market. Please continue to allow inverse funds. Thank you for taking the time to read this.