Subject: File No. S7-24-15
From: Michael DeSiano

January 30, 2020

I have invested in the stock market for over thirty years and studied market strategies and history.
I have bachelors degree in mechanical engineering and therefore knowledge of quantitative math which i use for investing.
I have read many articles on leveraged funds and made my own calculations and charts
My decision to invest in leveraged funds is based upon the above, my age and estate planning
I completely agree with the statement made by Pro Shares, copied below, and urge you not to implement restrictive and possibly unconstitutional regulations.

1. Bad for Investors. If the proposal is adopted, some investors who could benefit from the enhanced return and portfolio protection potential of leveraged and inverse funds could be prevented from buying them by an overly burdensome qualification process. Brokerage firms could even stop offering these funds altogether due to the difficulty of implementing the regulations.
2. Unnecessary. The SEC has not shown there is a problem that needs to be solved with respect to leveraged and inverse funds. They fail to show why these funds should be treated differently than tens of thousands of other public securities, each with their own characteristics and risks.
3. A Dangerous Precedent. Requiring you to qualify to purchase a security in the public markets would be an unjustified break with how the SECs regulation of the sale of securities in the public markets has worked for nearly 90 years. The proposal would be at odds with our long-standing system that gives investors and their advisors the freedom to make their own investment decisions.