SEC Comment Letter for ProShares Trust II (AGQ, EUO, GLL, SCO, UCO, UGL, ULE, YCL, YCS, ZSL, BOIL, KOLD, SVXY, UVXY, VIXM, VIXY) (CIK 0001415311) (AGQ) — Aug 11, 2011
ProShares Trust II (AGQ, EUO, GLL, SCO, UCO, UGL, ULE, YCL, YCS, ZSL, BOIL, KOLD, SVXY, UVXY, VIXM, VIXY) (CIK 0001415311)
Date: Aug. 11, 2011 · CIK: 0001415311 · Accession: 0000000000-11-048773
AI Filing Summary & Sentiment
Letter
August 11, 2011 Via E-mail Mr. Edward Karpowicz Principal Financial Officer Proshares Trust II c/o ProShare Capital Management LLC 7501 Wisconsin Avenue, Suite 1000 Bethesda, Maryland 20814
Re: Proshares Trust II Form 10-K for the year ended December 31, 2010 Filed March 1, 2011 File No. 1-34200
Dear Mr. Karpowicz: We have reviewed your first response lett er filed July 13, 2011 and have the following additional comments. Where i ndicated, we think you should revise your document in response to these comments. If you disagree with our co mment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our co mments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this inform ation, we may raise additional comments. Form 10-K for the fiscal year ended December 31, 2010
Financial Statements Report of Independent Registered Public Accounting Firm, page F-2
1. We note your response to prior comment 2. We are unable to concur that it is apparent that the audit opinion included with in your filing addresses the trust and each series individually. Quarterly Report for the Three Months Ended June 30, 2011
2. We were not able to locate your financial st atements in interactive data format using Extensible Business Reporting Lan guage or XBRL. Please advise.
Edward Karpowicz Proshares Trust II August 11, 2011 Page 2 You may contact Howard Efr on, Staff Accountant, at (202) 551-3439 or me at (202) 551- 3629 if you have questions regarding comments on the fi nancial statements and related matters.
Sincerely,
/s/ Kevin Woody
Kevin Woody Branch Chief
Show Raw Text
August 11, 2011
Via E-mail
Mr. Edward Karpowicz Principal Financial Officer Proshares Trust II c/o ProShare Capital Management LLC 7501 Wisconsin Avenue, Suite 1000 Bethesda, Maryland 20814
Re: Proshares Trust II
Form 10-K for the year ended December 31, 2010
Filed March 1, 2011 File No. 1-34200
Dear Mr. Karpowicz:
We have reviewed your first response lett er filed July 13, 2011 and have the following
additional comments. Where i ndicated, we think you should revise your document in response
to these comments. If you disagree with our co mment, we will consider your explanation as to
why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary
in your explanation. In our co mments, we may ask you to provide us with information so we
may better understand your disclosure. After reviewing this inform ation, we may raise
additional comments. Form 10-K for the fiscal year ended December 31, 2010
Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2
1. We note your response to prior comment 2. We are unable to concur that it is apparent
that the audit opinion included with in your filing addresses the trust and each series individually.
Quarterly Report for the Three Months Ended June 30, 2011
2. We were not able to locate your financial st atements in interactive data format using
Extensible Business Reporting Lan guage or XBRL. Please advise.
Edward Karpowicz
Proshares Trust II August 11, 2011 Page 2
You may contact Howard Efr on, Staff Accountant, at (202) 551-3439 or me at (202) 551-
3629 if you have questions regarding comments on the fi nancial statements and related matters.
Sincerely,
/s/ Kevin Woody
Kevin Woody Branch Chief