Subject: File No. S7-24-15
From: Chris Sturgis

February 19, 2020

I appreciate the opportunity to comment on this proposed new rule/regulation. I have held ProShares in one of my portfolios since early 2016. Symbol USD. This investment is up 373.92% and has split once 3:1 which tripled my shares. It has preformed well in up and down markets. It has enhanced my returns in this portfolio. Here are its annualized returns 1yr 110.38%, 5yr 32.36%, 10yr 27.92%.

I understand leveraged and inverse funds and their performance characteristics/risk. I hold 2 other leveraged funds. SPXL up 254.86% and TNA up 144.24%. I don't believe it is right for a third party to prevent me from making investment decisions. After all it is my money and I understand my tolerance for risk. I don't try and day or swing trade these I am long on all 3. On significant pull backs I may accumulate.

Last thought I truly believe it is absolutely critical to preserve the idea of free public securities markets. Where I as the investor have complete freedom to purchase the securities that I choose without the addition of government or regulatory agency imposed limitations on my choices as an investor. The governments' task is to make sure fund companies are properly managed and audited as needed. If I make a poor investment choice that is my responsibility and mine alone. I educate myself before making an investment. It is my opinion that this proposed new rule/regulation is unnecessary and one that will not serve a free market well.