Subject: File No. S7-24-15
From: Devin Gallagher

March 10, 2020

I understand the SEC's potential initiative, but think that these types of beta products serve a purpose, albeit should be a very small part of an investor's portfolio. The primary mechanic that should be explained to investors is that given the decay that exists with these products, when rolling forward the pricing, the product pricing can significantly deteriorate (time decay). As a result, these investments should be high conviction, have a targeted time line, and be a small amount of investment.