Subject: File No. S7-24-15
From: John Canney

March 12, 2020

We appreciate the SEC's concern for the welfare of investors, but hope that they will be careful and balanced in their approach to regulations that could put valuable risk management and portfolio balancing tools out of reach for most investors. Without the availability of TZA shares, we would have to hedge market risk using put options or financial derivatives that require constant monitoring and risks to invested principal that are no less than is the case for an investment in TZA shares. (for background, we have our investment portfolios with a household name firm that we know will go to any lengths to protect themselves from regulatory risk (and charge 8.75% on margin balances). So what will we do? Not sure, but probably the a vacation from investing in stocks.