Subject: File No. S7-24-15
From: vic talley

April 7, 2020

Enter your comments here.This not a good proposal for the following reasons:

1. This proposal reduces small retail investors options to hedge different types of risk and mitigate losses without change to the tax status of the components of their portfolio as well as betting against the market because market prices do fall and do it from their brokerage cash accounts.

2. This proposal increases small retail investor risks, costs and complexity by pushing them into margin accounts which are riskier than cash accounts, forcing them to short stocks or ETFs with additional set of rules for cash proceeds of the short sales and dividend liabilities, as well as getting into option and future trading.

3. This proposal paper over an urgent need for better investor education and market traded securities transparency.

Footnote: Though it may seem that my comments address only inverted/levered side of the levered ETFs activities, a similar argument could be made for the long side where small investors while keeping their defensive high dividend portfolio intact can hedge opportunity loss in tech.