Subject: File No. S7-24-15
From: Will McCauley

March 10, 2020

To Whom It May Concern,

I am writing to the SEC in opposition of proposed rule #S7-24-15. As explained to me in messaging from USAA, this rule would make it overly burdensome or impossible in some cases to buy mutual funds or notes that are leveraged or structured to deliver returns inversely related to overall market performance. I personally own two such inverse investment products and count on them to provide an insurance against large negative movements in the stock market, of which yesterdays 7% decline in the SP is a perfect example. Because I am invested in these inverse funds (and because they are leveraged to deliver outsized returns in such scenarios) I view yesterdays poor market performance with much less fear and dread than I might otherwise feel if I wasnt invested in these funds. I realize that, as a governmental regulator, your charge is to protect citizens from risks that they might not be aware of and ensure that financial markets are not havens for bad actors who would lead unsuspecting investors astray. I assure you that I fully understand the level of risk inherent in my investment strategy, and I do not need your protective actions in this area of my financial life. I HIGHLY recommend that you withdrawal this rule and focus on educating greater numbers of regular investors (like myself) as to what these types of investments are and how they can appropriately be incorporated into a larger investment strategy. Do not take away the main tool I use to create a balanced portfolio that will remain healthy throughout the markets up-and-down cycles. Such an action would be extremely short-sighted and force me to look into other investment vehicles to provide this balance, an activity I am neither interested in or have the time to research. I would be happy to provide further comments on this if needed. Thanks for your time.