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Robert Kronenberg Comment On Regulatory Notice 22-08

Inverse and Leveraged funds are an important part of ability to protect my portfolio. In down markets such as currently exists, in which the markets begin falling overnikght or in the free makret and acceIetate to downside the funds provide important day to day portfolio insurance without taking the much more extreme risk of short selling. In additiion, in strong bull markets the leveraged funds provide extra returns and allow for a hedging strategy in case of a market reversal as well as insurance against a catastrophic loss in a situation in which I am short.