Subject: File No. S7-24-15
From: Ron Shawley

February 25, 2020

Enter your comments here.
Im a small investor. I use inverse and leveraged funds now.
As everyone knows the markets go up and they go down.
Inverse funds allow me to make money when the markets turn to the down side.
This is the ONLY choice I have to stay invested when the markets turn down and hope to keep my assets from losing money. The buy and hold strategy is good for bull markets but cause financial damage in down turns such as the 2007 to 2009 correction. It took years to get back to break even.

A large investor can use the futures market to off set down side risk but I dont have that capital or the risk tolerance or the expertise to deal with futures contract.

inverse funds are my only option for down side risk or I need to use money market funds to get totally out of the market. Please do not take this flexibility away from a small like me.

I have used leveraged investing for a small percentage of my assets. I started saving late in my career and did not save enough for retirement. Im 67 and still working. Leverage investments allow me to accelerate my returns to try and make up for lost investment compounding through time. These leveraged funds have provided me a mechanism to in effect double my savings effort. With GIC rates at historic lows, I NEED some tool to grow my savings faster then the 5% rate of the TSX.

Eliminating the inverse and leveraged funds will hurt ME the small but it informed investor.
Let the markets regulate themselves by how much money goes into these investments. No demand, Im sure they will close.