Subject: File No. S7-24-15
From: Matt Elley

April 7, 2020

I've had an inverse fund throughout this bull market as a hedge on my portfolio. I lost a lot of money to this point that I am gaining back. It isn't fair to pull this investment option at this time considering others who have done this in their investing strategy. Additionally here are other reasons why this is not a good bill:

1. Bad for Investors. If the proposal is adopted, some investors who could benefit from theenhanced return and portfolio protection potential of leveraged and inverse funds could beprevented from buying them by an overly burdensome qualification process. Brokeragefirms could even stop offering these funds altogether due to the difficulty of implementingthe regulations.2. Unnecessary. The SEC has not shown there is a problem that needs to be solved withrespect to leveraged and inverse funds. They fail to show why these funds should betreated differently than tens of thousands of other public securities, each with their owncharacteristics and risks.3. A Dangerous Precedent. Requiring you to qualify to purchase a security in the publicmarkets would be an unjustified break with how the SECs regulation of the sale ofsecurities in the public markets has worked for nearly 90 years. The proposal would be atodds with our long-standing system that gives investors and their advisors the freedom tomake their own investment decisions.