Subject: File No. S7-24-15
From: Charles Stewart

February 25, 2020

Esteemed SEC Authorities:Feb 24th, 2020

First let me say thank you for the job you do for us as investors and for our country. We rarely take time to express our gratitude for a consistent, well done job and I just want to say Thank You for the confidence whereby I can invest and participate in the stock market, knowing the SEC will keep a level playing field and when necessary take care of any bad eggs. Without your work, I could not have most of my lifetime income invested in the market. Keep pressing on with the good work you are doing

Of course, I need to write this letter to add my voice and comments to the decision you are now debating on how to manage leveraged and inverse market funds. My retirement income was earned over 39 years of work in the oil industry. I was planning to work a few more years when a change in senior management along with an attractive retirement package convinced me the time had come to take retirement. Unfortunately, this early retirement choice left me with much more stock in the oil sector than I intended. Also the past few years have been good for dividends, but not conducive to selling oil stocks.

The leveraged and inverse funds you are considering to restrict or qualify buyers to hold are very important for risk management of my overall portfolio, especially when holding a higher ratio of oil stocks. Having leveraged funds allow me to buy fewer shares and as an inverse holding, its a suitable counterbalance to my oil stocks. You might be thinking, Well, this guy sounds like a knowledgable investor, so he will qualify to purchase these funds. But if your actions make these shares less visible, it will affect their value and could significantly decrease their value to me as a hedge or require me to tie up more investment dollars to maintain my current hedge/risk position.

The other thing Ive observed is these funds are thinly traded in the market most days. When you consider the trade volume, is the dollar value and volume on each of these funds significant enough to justify SEC action? While the total market for all inverse and leveraged funds may be a big number, I think you should consider each leveraged fund and how much trading goes on in each fund, not as an overall number. Personally, as an individual investor Im glad these funds are available to be used in my portfolio risk management and I appreciate the SEC for continuing to allow these funds to exist which enhances my market returns while balancing investment risk.

Thank you for the opportunity to comment on this and I appreciate your consideration of my views.

Chuck Stewart - Individual Market Investor