Subject: File No. S7-24-15
From: Dan McWhorter

March 13, 2020

This is a terrible rule. The market is already stacked against individual investors and removing our ability to easily trade LI funds further tips the scales against us, and especially during bear markets and periods of high volatility. LI funds are a great alternative to options and, although they come with increased risk of loss, they are nowhere near as risky as trading straight put and call options because they are less time-sensitive (please note I said less time-sensitive, I understand that LI products are derivative-based securities). I actively monitor all LI investments because I understand how they work (hence the word "Daily" in many of their names). Sincerely, Dan McWhorter