Subject: File No. S7-24-15
From: Roy Sowers

February 27, 2020

Today (2/27/20) is a great day to illustrate why contra funds are needed. SEF was up 4.6% today while most stocks declined. Using this fund as a hedge, I managed to be up 2.3% today.

Without the ability to hedge with contra funds, my alternative would have been to sell everything. Such an action by myself and others could have increased the selloff. Thus, contra funds help steady the market.

And please note that if I sell a losing position, I am out of that stock for at least 30 days (IRS), so I can't just jump back in quickly should markets stabilize. Utilizing a contra fund allows me to hold on to long positions and possibly provide cash for investment as the market bottoms.