Subject: File No. S7-24-15
From: Richard Brumtrop

March 21, 2020

I ran a very small advisory firm.I use profunds family of funds.Curtailing the use of short/hedging techniques would be punitive for my firm.The ability to use these techniques has kept me in business for many years.Leveraged funds are also important. To have this type of option is also important. We should not be handicapped when market direction changes.To be biased ,wanting the market to continue rising is foolhardy.Freedom of choice is what makes the american market the number 1 choice.ur comments here.