Subject: File No. S7-24-15
From: David Parker

March 11, 2020

As an experienced and knowledgeable investor I am aware of the risks associated with investing in leveraged and derivative fund products. However, I use these products in a rational manner to achieve specific investment objectives. I am aware of the historical risk of the funds I invest in and that potential that future risks could exceed historical risk. I am aware of the risk factors of the funds I invest in.

I do not think that the SEC should impose rules that would block access to products that I have willingly and knowledgeably decided to utilize in my portfolio. Doing so would not benefit me, only inconvenience me.

Investors should have personal freedom to decide how much and what type of risks they want to take. If there is an issue with investors taking on excessive risk with inadequate awareness then focus should be made on education, explicit disclosures, acknowledgement of acceptance of risks. Putting severe restrictions or blocking access is excessive and unwarranted.

David G. Parker