Subject: File No. S7-24-15
From: Sverrir Hauksson

February 20, 2020

IN my judgment leveraged and inverse funds such as those offered by ProShares belong in fairly experienced investor's portfolio. These may be less risky than options. On the other hand if they are traded as options the risk is no doubt greater than a typical option trade. If the trader or investor realizes that fact there is nothing wrong with the product.