Subject: File No. S7-24-15
From: Kevin Brockland

January 30, 2020

Leveraged and inverse funds are an important part of my investment strategy in which I can receive the benefits of a leveraged position on particular indices without the high risk incurred by taking leverage myself to achieve the same.

I have invested with ProShares leveraged ETFs for nearly 10 years. The risks are quite clear and easily understood. Taking actions to limit my ability to invest in these types of funds would be punitive action that would restrict free market opportunities.