Subject: File No. S7-24-15
From: Keith Ragan

March 23, 2020

Dear SEC,
I am a graduate with a Masters in Financial Planning from Cal Lutheran University in California. In our program, one of the most important investing topics, which applies to retail and institutional investors, is risk management.

However, not all investors are able to hedge their portfolios using SPY, QQQ, DJI futures, or Put options. Especially when we are talking about managing risk in SEP IRAs, 401ks, and traditional IRAs.

If it were not for my ability to use inverse index ETFs in my SEP IRA and my traditional IRA over the last three months, I would have had to close out all of my long-term positions in good quality companies at a loss, or worse left them in with no hedge to have the portfolios lose at least 40%.

We do not even know how bad this COVID-19 outbreak will last, so it is comforting to know I have these inverse index ETFs to counter the downturn. I use the SPXS, SQQQ and SDOW with a 25-percent of total portfolio value (prior to the COVID-19 correction). It has worked so well, that on the worst days, my main portfolio with $14000 only lost .04%. Almost a prefect hedge.

Additionally, this downturn is good for retail investors that can dollar cost average in each month, but for the other investors who put all of their assets in the IRAs and do not have access to hedges such as the inverse index ETFs will have to either tough it out or worst,, close out positions.

The financial markets are vital to consumers to be able to plan for retirement or legacy building. I feel that the need for inverse index ETFs, with an allocation of 25-percent of total value is ideal. No to be used to "short" the markets, but to help investors sleep better at night.

Additionally, for those investors that may have lost value, when the markets return to a bull cycle, they can use the inverse index bull ETFs to help get some additional gains back. Perhaps with the same 25-percent allocation, to help prevent excessive risk taking in retirement accounts.

Please consider situation and example above, and remember, we need all types of investors to make orderly and liquid markets. We do not want to have retail investors stop committing capital to great companies and being forever fearful.

We know that the markets will correct and even go into recessions, but history has shown that wealth building is exponentially increased when being in the markets on a post-recession or bear market upturn.

By having access to the inverse index ETF vehicles, I feel that we will be able to keep investors in the markets for as long as the markets are here.

Please keep the inverse index ETFs available for investors, and consider my 25-percent recommendation.
Thank you-
Keith J Ragan, MBA