Subject: File No. S7-24-15
From: Michael Ladd

April 3, 2020

The SEC should not restrict the ability of investors to access and use inverse ETFs or leveraged ETFs. Such ETFs are fantastic tools for investment advisors to do portfolio risk management and to increase an investors exposure to a certain theme without the use direct of futures, options or derivatives.

A perfect example is the use of an inverse equity ETF to modulate (risk mMage) the net equity risk in a clients IRA. For example, this year I have used an inverse equity ETF (ticker SH) to quickly reduce the equity exposure of various IRA portfolios that I manage which has facilitated my ability to generate a positive return, despite the fact that the stock market is way down this year. Currently, I hold ticker SH across most of the largest accounts that I manage which has allowed me to modulate (power) the net equity exposure to a level that I want. The approach allows me to target an equity risk level in a portfolio very easily and also makes the generation of positive equity return possible even if the market goes lower, by (e.g.) buying a group of individual stocks and concurrently holding ticker SH to lower the net equity weight.

Leveraged and inverse leveraged ETFs should also not be limited, as they can also be used to modulate the risk level of a clients portfolio to a certain theme and also allow a client to speculate With some of their assets, if they wish to do so. For instance, if a client wishes to speculate with a portion of their funds, i is possible to experience a very high return via a leveraged ETF - my experience is that many people speculate with a portion of their assets by typically do so by pursuing an individual stock that perhaps trades on the Pink doing that, they are taking too much specific risk. Using a leveraged ETFs allows the speculator to take almost exclusively diversified market risk, rather than specific risk which makes their risk exposure much easier to manage.

I and my clients sleep better at night knowing that we can manage and modulate the risk in portfolios via the use of inverse and/or leveraged ETFs. Especially in these turbulent markets, please do not take away my ability to use these products for my clients. These are fantastic risk management and modulation tools.