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

April 7, 2020

SUBJECT: Proposed SEC regulations for leveraged and inverse funds

To the Securities and Exchange Commission and Whomever else is involved with this issue -

I have been notified by ProShares about proposed SEC regulations that will make it much more difficult for investors to purchase leveraged and inverse funds. ProShares wrotethat "Brokerage firms could even stop offering these funds altogether due to the difficulty of implementingthese regulations."

If that happens, I will be forced to sue the SEC for my losses and punitive damages as well in court. I investedlarge portions of both my retirement and non-retirement money during the 2009 Great Recession in ProShares Ultra-Short SP 500 (symbol: SDS) and Proshares Ultra-Short Dow 30 (symbol: DXD) bear market funds.

It is important for the SEC and ProShares to not change their rules regarding the availability and purchase ofthese two particular inverse index funds. symbols SDS and DXD.

Ipurchased most of my shares of these SDS and DXD funds in 2009 because:
a) the stock market was in free-fall,
b) all of the financial experts said that there was always a "double-dip" in the recovery of these type of events (but oddly, there has not been a double-dip in the recovery of the 2009 Great Recession),
c) my losses would be limited to the amount of money that I spent purchasing shares of these SDS and DXD funds. Unlike shorting individual stocks, I would never be required to put up additional money.
d) I believed that I could hold on these funds as long-term investments because no one said at the time in 2009 that these funds were not for long term investment.

Again, losses are limited to the shares of these funds that are purchased, so purchasing them was/is not like shorting individual stocks. I know that as a fact, as I watched my shares of these two ProShares funds lose approximately 96% of their value over the past 11 years, since 2009. I was never required to put up additional money to purchase additional shares to backstop losses.

I have been waiting since 2009 and continue to wait for the next recession (second Great Depression).. That is when I intend to sell all of my shares of these funds.

So again, I need SEC and Proshares rules regarding the availability and purchase of SDS and DXD funds to remain the same.

Sincerely,
John Chin