Subject: File No. S7-24-15
From: Reid Winder

February 21, 2020

Leveraged Funds have been an important tool in my personal investing and for my clients. Used with risk management tools they can make a huge impact on investment returns. I have never used inverse funds but I like to have them as a tool if I feel the market is falling and I would like to take advantage of inverse funds vs. shorting where I can get a margin call if I am wrong. Also, being able to place stops on my leveraged positions or inverse positions can limit my downside. Please do not take these tools away from the investment world.