Subject: File No. S7-24-15
From: Harry Plummer

March 1, 2020

I am OPPOSSED to the revisions proposed by S7-24-15 for the following reasons:

1) LOSS of CONSERVATIVE HEDGING. If these changes are enacted I will lose my ability to hedge positions which I may have in my cash brokerage accounts. Additionally I will lose my ability to hedge holdings in my IRA accounts.

2) INCREASED PORTFOLIO RISK. If these changes are inacted in order to hedge my positions I would have to convert my cash accounts to margin accounts so that I could short shares or buy long puts. I consider both of those options more risky to my financial health than buying an inverse ETF. It exposes me to counterparty risk and alot more loss of capital risk.

3) UNNECESSARY GOVERNMENT MEDDLING. I find it extremely offensive that I would need to quailfy which is basically the same as asking permission, from a government agency in order to invest/spend my money as I see fit I am well aware of the risks involved with leveraged ETF's and inverse ETF's.

4)UNFAIRLY PENALIZES PRIVATE INVESTOR. Without a doubt institutional investors will be able to easily quailify, whereas the small private investor will face a more challenging situation. If you were really concerned with the effect inverse and leveraged ETFs have on the market, the appropriate course of action would be to limit/cap the ability of institutional investors with their large source of funds to take a position in ETFs.