Subject: File No. S7-24-15
From: Jason Alban

February 27, 2020

This would be just more red tape and cya. These are valuable investment tools. I believe all chosing to purchase these etfs understand the inherent risks. Many use these to hedge directional market ebbs and flows against other portfolios. There are likely many reasons why investors use these instruments and the government shouldn't purport to know why or look at these investments as one sided. Those in them know they can gain or lose money like any other investment freely traded. Fixed income decisions are not much different in that you are taking a view, assessing the risk and purchasing something that could also gain or lose value if freely traded. In short, don't stifle or over-regulate this segment of the market. A prime example of this is the past two weeks (last two in Feb) where markets drastically changed and vix rocketed higher. These etfs are made for these types of environments.