Subject: File No. S7-24-15
From: Donald Mullen

February 20, 2020

I have been an individual investor for many decades, studying many different investment vehicles. Through this, the best one I've found is Proshares TQQQ. Contrary to the articles warning about holding this leveraged fund, I have found that buying and holding it is extremely profitable (50% average annual returns) with an extremely low risk, because it is attached to the well-known NADSAQ.

I've run countless hours of what-if calculations looking for hidden dangers that are waiting to consume my retirement savings. And the biggest danger is its volatility. Yes, it can experience deep pull downs, but when it recovers, it always returns to its long term upward trend line. So, if one can ride out the time to recover, which may be days or even a few years, so what? By its very nature, it always returns to its original trend line, resulting in zero loss to the investor. Do the math.

By the fund's basic nature, it can never go to zero (as ordinary stocks can go bankrupt) unless the NASDAQ drops more than 33% in one day. Even then, when the NASDAQ recovers, so will TQQQ. At that time, yes, the remaining amount will be small. But it will be recovering at 3x the speed of the normal markets. And the huge profits made through the years preceding such a market collapse will far outweigh the rare case of such a crash, which I don't believe has ever happened to that degree since the DOW (or equivalent) began in late 1800's(?).

If one thinks this fund is dangerous, consider the following: If one invests $1,000 and nets average annual returns of 50%, as it has for the last 10 years, and holds it for only 5 years, the original $1,000 will have grown to $7,594. Then if the fund losses 80%, the owner will still have a $500 profit Point is the long-term profits far outweigh potential losses.

TQQQ has been extremely important to enhance my, and many others, retirement funds, while much safer than normal stocks, that do sometimes go bankrupt.

The amazing success of our country is based on our individual freedoms. Those of us that are free to invest in the TQQQ insist on maintaining that choice.

If a government wants to remove leveraged funds from the citizens through strict controls, then they also need to bar the use of ordinary stocks that do go bankrupt. Las Vegas, with its guaranteed long term losses should also be stopped, along with one of the worst financial places - the government run lotteries.

Thanks for hearing our concerns.