Subject: File No. S7-24-15
From: Thomas Muller

March 12, 2020

I oppose the Proposed Rule #S7-24-15 because it would detract from my ability to enhance returns in an up market, by limiting such instruments to Qualified Investors.

The very term Qualified Investor is an anathema to people like me, because many people who meet the criteria do so through inheritance or high income from outside the finance world and have very little knowledge about managing money. I spent my forty-year career in Finance and Accounting, but modest income and the responsibilities of raising a family leave me not quite Qualified. However, I manage and grow my wifes and my portfolio, despite needing $24,000 per year for retirement distributions. We own mostly blue chip stocks, averaging 3-5% dividends, but occasionally buy growth stocks, bonds and sector ETFs to juice growth. I use stop losses to limit downside on the more volatile instruments and usually sell before loss on a single security reaches $1,000. Our overall portfolio did not beat the SP 500 last year, but it was/is much less volatile and still yielded a healthy 10.4%.

I submit that I am better qualified than most Qualified Investors and should not be stripped of the ability to use leveraged and inverse funds as financial tools. If you must take them away from the general public, why not expand the definition of Qualified Investor to include people who have substantial vocational experience in Finance and Accounting? While most with a CPA or Series 7 license would qualify, those with experience as an unlicensed public accountant, a corporate accountant or controller, or a decade or more of personal portfolio management might also qualify.