Subject: File No. S7-24-15
From: Raymond Davis

March 13, 2020

As a Registered Investment Advisor who runs two investment portfolios with discretion on all client accounts, I use levered inverse funds to hedge/protect client assets during down markets. We have a considerable number of IRA's that are not allowed to invest in options to protect their assets so we use the levered inverse funds. The current market decline has the market down 16.67% year to date and our portfolios are only down 3.75% and 0.43%, saving our clients the pain and anxiety of seeing their assets decline 16%. One of the reasons I risked everything by leaving Merrill Lynch to start my own firm was because Merrill Lynch advisors were shut down by the regulators from using these products in 2009. I believe to best serve my clients I need the ability to use what ever investments are available to grow my clients assets as well as to protect them in bad markets.