Subject: File No. S7-24-15
From: Jennifer Brown

March 12, 2020

I have used ProShares leveraged funds for may years. I am responsible with our investments in that I have a small portion in leveraged funds and a larger portion in more traditional funds. This allows diversity in our portfolio.

I understand that a leveraged fund involves more risk than a traditional fund. However, I don't feel it is any more risky than investing in a single company stock, which could have a value that plummets practically overnight with the release of a negative news article or if the business suddenly closes.

It is the responsibility of the investor to do their research and understand what they are investing in. I have done a lot of research on the funds prior to putting any money into a leveraged fund. At that point, I put a small amount in the fund to get a feel for how the fund performs and my comfort level with it. I have been very happy with my investment in ProShares' leveraged funds, I feel like I manage it well, and it has become a staple part of my portfolio.

I do not think it is the responsibility of the SEC to require me to in some way "qualify" to continue my investment plan. I think this is a dangerous precedent. I choose to invest through a platform that allows me to buy stocks and ETFs on my own, without using a financial professional. To require me to qualify in some way, is against the idea of having free and open markets, where someone like me can research, decide and then purchase stocks and ETFs as I see fit for my goals and within my financial comfort.

As will all investments, it is a calculated risk. That risk is the responsibility of the investor to determine their comfort level. I ask the SEC to allow leveraged funds to continue to be traded as is, with no qualification process.