Subject: File No. S7-24-15
From: John Denholm

May 4, 2020

For thirty plus years I've been managing our retirement funds successfully, and when equity markets are very overvalued use ProShares inverse funds for one purpose: to hedge macroeconomic risk. I thoroughly understand the leverage components and that their value changes with daily up and down movements of respective indices.

To remove my access to do this efficiently would force me to use a few call and put options, which I really don't understand well, or force me to not be able to hedge risks during periods of high market volatility and in bear markets.

In short, it would unlevel the playing field a private investor like myself would have with commercial hedge funds and institutions.