Subject: File No. S7-24-15
From: Bruce MacNaughton

March 19, 2020



I am writing as an individual investor for my own accounts.

At 90 years of age, I have become a conservative investor.

I have been buying and selling various equities for some 70 years,

My background

A college drop out
Oil field trash
A Marine
A BS in Engineering
A Registered Professional Engineer
A CEO of a public company
A self made multimillionaire

I currently manage more than $10 million in multiple accounts. In one account, I increased its value 15 times in 30 years.

In other accounts, I quite successfully utilize leveraged funds. The percentage allocations in these accounts range from 2 to 5%. I have made the decision not to utilize inverse funds.

I want at least a 10% return every year. I have been able to surpass this goal over the years.

I really dont want the SEC to restrict my utilization of leveraged funds which have enhanced my returns over the years. Any restrictions on my ability to utilize leveraged funds would be an effort on the SECs part to teach old dogs new tricks..

Since there is considerable risk in the equity markets, the SEC could do our citizens a favor by not allowing any trading in equities

My main concern regarding your proposed rules on leveraged and inverse funds is where one would start and where one would stop with the rule making.

Could the SEC possibly restrict the buying of any stocks because they have inherent risks? Buying stocks has been the best place to put your investment funds into over the long haul.

I would not like being responsible for the rules under consideration by the SEC. Who in the SEC would take personal responsibility for the proposed rules? If no one, then maybe the proposed rules should be reconsidered.

The results of most actions, endeavors, etc. are usually enhanced as the perpetrator gains experience.

Only an idiot would continue buying an instrument that constantly lost money. The idiot would have learned not to buy that instrument again. He would keep buying something else until he found something that he was happy with. There is always the possibility that he would lose everything as a result of his decisions, not the SECs.

I learned the hard way not to buy on margin. A $100 call taught me that lesson some 65 years ago.. I have not borrowed money for any purchase other than a home. If you dont have the money to pay for an item, you dont need it.

The best way the SEC could protect the public is to develop rules that prohibit the stockbroker from selling the wrong securities to an inexperienced customer.

Is it possible to create rules that would prohibit the broker from selling a customer an investment that doesn't fit their needs.

At one time, I had a small interest in a brokerage house that used cold calls and a hard sell to peddle stocks. When I saw how this house worked, I got out of that investment.