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) — Dec 1, 2015
ProShares Trust II (AGQ, EUO, GLL, SCO, UCO, UGL, ULE, YCL, YCS, ZSL, BOIL, KOLD, SVXY, UVXY, VIXM, VIXY) (CIK 0001415311)
Date: Dec. 1, 2015 · CIK: 0001415311 · Accession: 0000000000-15-055845
AI Filing Summary & Sentiment
File numbers found in text: 001-34200
Letter
Mailstop 3233 November 30 , 2015 Via E -mail Mr. Edward Karpowicz Principal Financial Officer ProShares Trust II . 7501 Wisconsin Avenue, Suite 1000 Bethesda, Maryland 20814
Re: ProShares Trust II Form 10-K Filed March 2, 2015 File No. 001-34200
Dear Mr. Karpowicz :
We have reviewed your November 5, 2015 response to our comment letter and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to y our facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our reference to prior comment is to the comment in our October 8, 2015 letter .
Form 10 -K for the year ended December 31, 2014
Item 15. Exhibits and Financial Statement Schedules, page 149
Statements of Financial Condition and Schedules of Investments
1. We no te your response to our prior comment 1. In reference to the example we previously provided, we continue to be unclear why you have not separately reported the accumulated appreciation amount for the futures contracts from the schedule of investments on your statement of financial condition . Please provide us with further information and cite any relevant accounting literature in your response. In your response, explain to us why you have not separately presented the amounts due to/from brokers as a result of variation margin requirements from the value of futures contracts.
Mr. Karpowicz ProShares Trust II November 30 , 2015 Page 2
Additionally, please tell us whether the $18m you have on account with brokers for futures contracts includes amounts paid to satisfy variation margin requirements.
You may contact Peter McPhun , Staff Accountant , at 202-551-3581 or the undersigned at 202-551-3438 with any questions.
Sincerely,
/s/ Robert F. Telewicz, Jr.
Show Raw Text
Mailstop 3233
November 30 , 2015
Via E -mail
Mr. Edward Karpowicz
Principal Financial Officer
ProShares Trust II .
7501 Wisconsin Avenue, Suite 1000
Bethesda, Maryland 20814
Re: ProShares Trust II
Form 10-K
Filed March 2, 2015
File No. 001-34200
Dear Mr. Karpowicz :
We have reviewed your November 5, 2015 response to our comment letter and have the
following comment. In our comment , we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comment applies to y our facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Unless we note otherwise, our reference to prior comment is to the comment in our October 8,
2015 letter .
Form 10 -K for the year ended December 31, 2014
Item 15. Exhibits and Financial Statement Schedules, page 149
Statements of Financial Condition and Schedules of Investments
1. We no te your response to our prior comment 1. In reference to the example we
previously provided, we continue to be unclear why you have not separately reported the
accumulated appreciation amount for the futures contracts from the schedule of
investments on your statement of financial condition . Please provide us with further
information and cite any relevant accounting literature in your response. In your
response, explain to us why you have not separately presented the amounts due to/from
brokers as a result of variation margin requirements from the value of futures contracts.
Mr. Karpowicz
ProShares Trust II
November 30 , 2015
Page 2
Additionally, please tell us whether the $18m you have on account with brokers for
futures contracts includes amounts paid to satisfy variation margin requirements.
You may contact Peter McPhun , Staff Accountant , at 202-551-3581 or the undersigned at
202-551-3438 with any questions.
Sincerely,
/s/ Robert F. Telewicz, Jr.
Mr. Robert F. Telewicz , Jr.
Branch Chief
Office of Real Estate and
Commodities