Subject: File No. S7-24-15
From: Kevin zagortz

March 12, 2020

Please do not pass this. Leveraged and inverse ETFs do serve a purpose in portfolios. They allow better structuring of portfolios and risk allocation as well as tax management. They also allow retail investors to structure portfolios more similarly to institutions. They should not be viewed in isolation, for instance inverse equity ETFs have done poorly but that doesnt mean they shouldnt exist. I have been able to take more long SP500 exposure because Ive been able to buy inverse short small cap ETFs. Even though the inverse shorts lost money I made more money. Also, a bear market inevitably looms so taking away the ability of investors to profit from it seems terribly backward looking.