Subject: File No. S7-24-15
From: Larry Flewelling

March 12, 2020

I would like to ask the SEC if they buy life insurance to protect their families, purchase auto insurance, or home owner's insurance again to protect their families? If the answer to those question is yes as I imagine most responsible people would answer yes, then I must ask why would you deprive me the right to purchase insurance on my portfolio? I have worked my whole life and made investments that amount to much more value than a house, or automobile. Why would I be foolish enough not to want the right to protect my investments when the current cycle turns into a bear market? A perfect example was during the NASDAX crash of 2000 when I used ProShares inverse funds to protect my downside. The people who use inverse and reverse funds during the downtrends come out of the down market with funds to invest which helps the indexes to turn bull again. Why does the SEC want American investors to become distrustful of the markets? We are investors, and we want every opportunity to become successful. I for one would pull my money from the markets, and I would move to more tangible investments if you remove my right to protect my portfolio I am just an average guy who hangs out with other average guys, and we are of the same mind on this issue. In conclusion, I will say that if the SEC wants to see a lot less money coming into the market, then go ahead and take away our right to using ProShares funds Sincerely Larry Flewelling