Subject: File No. S7-24-15
From: Li Fan

May 11, 2020

To whom it may concern,
I hope this message finds you well. I would like to provide below comments for your review and approval in order to keep my ability to buy leveraged and inverse funds in the future.
1To protect my whole familys portfolios:
My whole family long the Asia/US markets via local ETFs in China for years. However, there is no way for them to hedge their positions to avoid any market big drop/black swan event because of the local market limitation (not a mature enough market, so there is no product for them to hedge/protect their positions).
As the only family member who lives in the North America. It is very important to my family to keep my ability to buy leveraged and inverse funds. Therefore, the whole familys risk would be hedged accordingly.
In fact, those leveraged inverse funds perfectly hedged their positions during March crisis since they all struggled in the local ICU and could not sale their positions on time. ( They are all good now)
2) Fine knowledge of the product:
I used to work for D.E. Shaw (hedge fund) as an investor relation specialist to serve both clients and the fund admin team. I am currently working for a local big bank and still support the front-line sales (ie: personal bankers, financial planners). Therefore, I deeply understand how those funds work. I fully understand those funds performance characteristics. As an MBA CFA holder, I have confident I do not need a third party to evaluate my capability to do so.
3) True North Strong and FREE:
My family paid a lot of money to help me to move to Canada. I believe the core value here is Freedom and Democracy. For investment side, it is very important to preserve the long-standing free public markets where investors have the freedom to buy public securities without additional government-imposed limitations on our choice.
God bless you, God bless America.
Best Regards,
Li Fan