Subject: File No. S7-24-15
From: Jerome Siegel

February 29, 2020

I have been trading in proshares TQQQ and a number of other leveraged and inverse leveraged ETFs (contraETFs) such as those offered by Proshares.
These funds are important to helping investors like myself to manage risk and help navigate increase volatility and provide leverage during wide swings in the market.
At times when volatility is low, I have also purchased UVXY to provide a hedge.
Although I trade options including calls, puts, and spreads, I use the leveraged funds as an easier way to manage risk.
I hope the SEC does not discourage the public use of these leveraged ETFs as they are an important part of my trading and public trading.
Lastly, I trade in both TD Ameritrade and Schwab and both brokerages make me aware each time I place a trade that I am using leverage and that there is risk to using these instruments. I switched trading accounts from Vanguard last year after having been a client of theirs for over 30 year. Vanguard made the unilateral decision to stop clients from purchasing leveraged and inverse funds. I moved all my money from Vanguard. I think it is bad and hypocritical when they decided this and yet at the same time allow a client to place a risky trade in a biotech stock or fund or other speculative low priced stock and lose all the principal value. I hope the SEC does not change or discourage investment in leveraged and inverse funds. I would be happy to discuss my opinions any time.