Subject: File No. S7-24-15
From: Laszlo Csanky

February 21, 2020

Release No. 34-87607, November 25, 2019

These funds are better suited for portfolio balance and protection than options or futures. Therefore they are important for many investors.

The risk these funds represent is less than the risk of options or futures since they move slower than options or futures.

These funds do not decay in time like options.

These funds are not different from other index funds.

Understanding the characteristics of these funds is simpler than understanding options or futures. Understanding funds and percentages suffices.

This is another burdensome regulation without demonstrated need.

This regulation may be an attempt to steer money toward the option and futures markets.

The regulation is also adverse to the fee market of securities.

Do not fix what is not broken.


Laszlo Csanky