Subject: File No. S7-24-15
From: Dale Waltman, MPT

January 29, 2020

Regarding S7-24-15. I was advised by ProShares Funds that this proposal will provided increased burden/qualifications for participation in inverse and leveraged funds, and subsequently elimination of the individual investor who feel they understand, and are willing to take the calculated risk in, and thus be exposed to the potential benefits that such funds provide to our portfolio.
Excessive burden/qualifications will only benefit large inventors/investment organizations who have the designed capacity to manage such burdens, and thus are exposed to far greater returns than the small investor this may give a hint of a pay to play model.
Small individual investors should have the same exposure and rights to investments w/o burdensome qualifications. I would like to think how a free market should work.

Respectfully submitted
Dale Waltman MPT