Subject: File No. S7-24-15
From: ShiouChin To

March 17, 2020

Re: Comment on Proposed Rule #S7-24-15

My name isSusan ShiouChin To.I am a knowledgeableinvestor who actively manage my investment portfolioprudently. I assess risk carefully and do the investment based on my risk tolerance. Leveraged and inverse funds are very important to me as they allow me to seek enhanced returns and to help me protect my portfolio. As I have read the prospectus of L I funds regularly, I fully understand the characteristics and the financial risksof these funds. After a detail analysis, I am willing to add these funds to become partof my assets allocation in order to balance my investment portfolio.

I thoroughly understand LI fund is one type of Bear Funds. It pursues daily leveraged investment objective that is inverse to the performance of its underlying index. It has high volatility because it seeks daily leveraged investment results and may lose more money in market conditions that are adverse to its investment objective.Nevertheless, I monitor the performance of these funds daily as I log into my brokerage account numerous times a day to make a sensible decision when to buy and when to sell . I use a spreadsheet to calculate profit and loss from these funds multiple times a day. The resultsfrom this calculationand my risk tolerance allow me to determine a sensible time to trade this fund.

I frequently receive warning messages from the brokerage firm as well as the disclosure of the Prospectus telling me the potential risks involved when investing in L I Funds, I fully understand the risk involved and I believe I can tolerate it. I am convinced this fund is an excellent investment vehiclefor me to balance my portfolio.

As I have the knowledge , skill setand the ability to analyze the L I funds and their performance characteristics, I don't want a third party to evaluate my ability to do so and potentially preventing me to trade these funds. I believe my prior experience in trading LI Funds should automatically qualify me to continue trading LI Funds.

Please give me the freedom to make my own investment decision.

Thank you for your attention,