Subject: File No. S7-24-15
From: P Franz
Affiliation: na

May 11, 2020

Proshares Ultra VIX short term futures ETF with the symbol UVXY is not suitable for retail investors, but somehow can be purchased by anyone with a computer and online brokerage account.

Since the experts at Proshares invented the ETF in October of 2011, the ticker symbol UVXY has decreased in value from $240 million dollars PER SHARE to as low as $10 PER SHARE in early 2020. There is a problem with this ETF.

Due to the SEC proposed rule changes S7-24-15/ 34-87607, Proshares is sending letters to shareholders claiming Proshares leveraged and inverse funds "enhance investors returns and protect portfolios". In reality, Proshares ticker UVXY has taken $8.8 billion in retail investors savings and retirement accounts and lost 99% of shareholders money. There is a problem with the Proshares vix short term futures ETF (uvxy) The ETF is dangerous as it traps the retail investor in non recoverable losses. UVXY retail investors need the help of the SEC.

Second, due to the SEC proposed rule changes S-7-15-34, Proshares is sending letters to shareholders claiming shareholders understand leveraged and inverse ETFs and try to coerce shareholders to write comments of understanding for the proposed SEC rule changes. (S7-15-24).

In reality, Proshares sends the prospectus (many times only an email link) months after the purchase of the ETF. Furthermore, Proshares sends a 160 page prospectus written by an expert in Wall Street financial, legal, and boiler plate terms. In addition, in October of 2019, Proshares created more disclosures in a 170 page Statement of Additional Information. In reality, a retail investor would need to hire an expert to read 300+ pages (at great expense and time) to help understand Proshares complex derivative filled ETFs.

In reality, the Proshares ETFs are so complex, Proshares CEO told the Washington Post, that Proshares biggest challenge is to train Financial Advisors about Proshares complex, risky derivative filled ETFs. Generally, retail investors have less training than a financial advisor so it is not realistic to think a retail investor understands the complex prospectus and Proshares ETFs.

In reality, when there is a problem with an ETF, Proshares tries to HIDE behind prospectus disclosures.

Proshares is NOT being transparent. Proshares CEO is a securities lawyer with a MBA who is gaming the system and the SEC in order to benefit Proshares company while harming retail investors. The above are just a few of the many unfair, deceptive, and abusive acts and practices of Proshares. Retail investors need the SEC to investigate and take action against Proshares Ultra VIX short term futures ETF with the ticker symbol uvxy.