Subject: File No. S7-24-15

March 11, 2020

I am writing Re: The SEC proposal of a new regulatory approach for funds use of derivatives (L I Funds).
I believe that most people (like myself) who buy and trade L I funds at discount brokerage firms fully understand the characteristics and risks associated with them and do so because of the potential gains derived. Additionally, brokerage firms issue statements to their clients (see below from TD Ameritrade).

Further, any attempt to regulate this activity and have the Brokerage firm decide who can or cannot trade/invest in L I funds is akin to having the fox stand guard over the hen house. Brokerage firms would prefer clients deposit money in an account and would gladly manage the account for a fee. This may be a good service for some but would deny the individual active trader/investor the opportunity to take advantage of a free-market system that he/she chooses to engage in at their own risk.

As an active trader/investor in L I funds I monitor my holdings multiple times in a day, every day, on my smart phone and can manage the account as often as I wish.

I do not want anyone telling me I cant do that. I want to make my own investment decisions and know fully the risks involved.

Finally, I would suggest that the experience level of someone who has a history of trading/investing in L I funds should be taken into consideration. What if a person has consistently traded/invested in these funds for three or more consecutive years shouldnt that person automatically qualify to continue trading LI Funds even under the proposed regulations?
Personally, I have been trading/investing in L I funds since early 2012 and believe that should automatically qualify me to continue trading LI Funds even under the proposed regulations.

Statement from TD Ameritrade Inverse and short ETFs entail unique risks and require active monitoring and management, as frequently as daily. They may not be suitable for all investors and are typically intended for short-term trading. They're similar to leveraged ETFs, seeking to provide an opposite or inverse return on an underlying index. These returns are generated on a daily basis. Due to the impact of daily compounding, do not expect the promised daily leverage of these returns to continue for more than a day. These funds may not have the same tax benefit as other ETFs since they generate their returns by using derivative positions. Please see the displayed page for more information. ETF research - ETF Market Center Chat Live with a Person. Related Help: Risks of leveraged and inverse ETFs, Research ETFs, What are leveraged ETFs?

Ralph Torrelli