Subject: N/A
From: Normand Bourdua

Mar. 17, 2020


Comment on SEC Proposed Rule #S7-24-15: 

I would be financially very harmed if the SEC prevented me from using the ProShares funds to protect and enhance my portfolio. As an example, with the rapid fall of the market from Feb 24th to Feb 28th, I was able to use the triple leveraged inverse funds to protect my portfolio from falling dramatically. These funds did not increase my risk, they reduced it! I was able to save $60,000 in losses because of them. In good times they also allow me to keep some cash in by investments while staying fully invested. This gives me the ability to be nimble in protecting gains, since if I used all of my cash, I would not be able to change a positions without risking a trade violation in my 401K. This is because they require three days for cash to be available for trading. Please DO NOT change my ability to protect my portfolio. If would force me to invest less due to the inability to reduce risk. 

Each investor makes his decisions knowing the risks, if he is not a fool. Please do not change the rules for careful investors to protect fools. Fools will always lose money regardless of what rules you create. The change could hurt Proshares, and the careful investors who depend on their services. 

A market free of restrictions other than those designed to prevent cheating is the healthiest instrument to keeping investments coming and benefiting the economy. 

Normand Bourdua