We are deeply concerned that the Investment Company Institute (ICI) Letter lays out a set of changes to the Proposed Rule which wold effectively negate the derivatives exposure limits in the rule and render them useless as a tool for controlling speculative leverage at registered funds, as is required by the 1940 Act. …This change would not simply modify the relative weighting of derivatives exposures, but would result in a massive increase in the absolute limit on derivatives risk exposure.