Subject: File No. S7-24-15
From: Gustave Kein

February 21, 2020

I am a 57 year old retail investor with intermediate experience in equities investing. ProShares products such as DXD, QID, REK are part of my portfolio and have been since 2016. There have been gains and losses. As one who reads extensively about the stock market and these specialized leveraged and inverse funds, I know the risks involved.

These products allow me to put into practice my theories of market performance in a simple framework. If these funds were removed from my trading options I would be limited to staying on the sidelines in cash. Large financial institutions and hedge funds can short as they wish but I would not be able to participate in a market reversal when it comes (and it always does).

This rule is bad for investors as it places too much regulations and burdensome polices in place that my seriously limit my future trading and destroy the value of the positions I currently hold.

This rule is also unnecessary . Tens of thousands of stocks, bonds, and commodities and traded everyday by retail investors with our without advisors. Money is made and lost as educated investors make decisions and take responsibility for the results.

Finally this is a bad precedent for the SEC to set. The Commission has not interfered with individual investors right to choose their funds or stocks based on their own theories of future market performance. Why these funds? Why now? Is this an effort by large financial firms to edge out the limited ways I and other individual self-directing investors can short the market? If this rule passes, what is to stop the Commission moving forward with more restrictions on other types of funds like bond funds (my mother lost $18,000 on one big firm fund last year). She new the risks and took the loss.

I urge the the SEC to reject this rule and allow individual investors the right to continue to participate in these valuable funds.