Subject: File No. S7-24-15
From: Peter Di Giulio

March 10, 2020

My comments concerning SEC Release No. 34-87607:

I very much understand leveraged and inverse funds, and strongly object to a financial discrimination being put place in the use of these financial instruments.

I have a masters degree in applied mathematics and well understand the risks associated with leveraged and inverse funds, and that they
are leaky financial instruments when held for an extended period of time. Moreover, the brokerage firms with whom I trade these funds all regularly provide a prospectus and disclosure of the risks involved.

I've taken personally acceptable risks with my eyes wide open using these funds, carefully following the market every trading day. I've been a bear during the sustained rise of asset prices, and of course have losses with these instruments. That is the risk I knowingly took.

While this has been a long, sustained bull market, asset prices do not monotonically rise forever, as we are now seeing. With the market now meaningfully reverting towards the mean, I am enjoying profits.

It would be an outrage and unfair for the financial instrument to have been acceptable during the long market rise (where market bulls were profiting from my losses), but no longer (based on a financial discrimination that benefits the wealthy) when my bearish positioning is now reaping profits in this falling market.

Peter C. Di Giulio