Subject: File No. S7-24-15
From: Joshua Mauldin

March 22, 2020

I was deeply disturbed to receive a message from ProShares referencing a proposed SEC rule that could limit who may trade leveraged/inverse ETFs. These products are key to my strategy and I would be devastated if I could not trade these securities anymore and/or trading volume is reduced due to these proposed restrictions. I've developed a strategy around volatility and 3x leveraged instruments and I've started to have significant success. In addition, while the stock market has crashed over the last month, I've been able to use these securities to completely offset losses across my portfolio in a cost efficient manner.

I really can't understand why the SEC is proposing any rules here around leveraged/inverse ETFs. I know these instruments can move quite quickly and traders need to be careful. But, that's the trader's responsibility to understand the instrument that they are investing in. I thought the SEC's responsibility was to ensure an trader receives adequate disclosures about the risks of an investment but not to take away necessary trading options. This seems like an overreach by the SEC and it is yet another example of how wealthy individuals can gain access to premium products that regular people can't. I strongly encourage decision makers to throw out this proposal and not restrict access to these securities.