Subject: File No. S7-24-15
From: Chad Cunha

March 13, 2020

The risks investors assume when purchasing securities subject to the proposed ruling are fully disclosed in the respective prospectuses. It is wholly up to the investor to inform themselves of said investment risks prior to their investing in them. Is is not under the purview of the SEC to make a determination as
to whether an investment is/is not prudent. Further, elimination of inverse ETFs greatly restricts shareholders capacity to hedge themselves in retirement accounts. The use of puts to hedge poses far more risk to investor loss then an appropriate ratio inverse hedge.
Thank you for your consideration of my comments.