Subject: File No. S7-24-15
From: robert burns

March 12, 2020

I spent a 40 year career as a stockbroker and a trust department investor. I am financially qualified to assume the risks associated with leveraged inverse investment elf's.I monitor the elf daily and am fully aware of liquidity and pricing risk.Potential owners of these elf's should adhere to proper portfolio diversification norms so as to mitigate the associated leverage risks.Buyers of these products should be provided with a prospective to outline the inherent risks.....if this is done then the person should be able to participate as he chooses