Correspondence 0001137360-24-000387 from VanEck ETF Trust (CIK 0001137360)
VanEck ETF Trust (CIK 0001137360)
Date: May 23, 2024 · CIK: 0001137360 · Accession: 0001137360-24-000387
AI Filing Summary & Sentiment
File numbers found in text: 333-123257, 811-10325
Letter
Washington, D.C. 20549 Attn: Emily Rowland, Division of Investment Management (File Nos. 333-123257 and 811-10325)
Re: VanEck ETF Trust (the “Trust”)
Dear Ms. Rowland:
We are in receipt of your comments regarding the registration statement on Form N-1A (the “Registration Statement”) for the Trust with respect to VanEck China Bond ETF (the “Fund”), a series of the Trust, filed with the Securities and Exchange Commission (the “SEC”) on March 25, 2024. The Trust has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement on its behalf. Below, we describe the changes that have been or will be incorporated into the Fund’s Registration Statement in response to the Staff of the SEC’s (the “Staff”) comments and provide any responses to or any supplemental explanations of such comments, as requested. Capitalized terms used in our responses have the meanings attributed to such terms in the Registration Statement, unless otherwise noted.
GENERAL
Comment 1. Please respond to all comments in a letter filed as a correspondence on EDGAR and email a courtesy copy of the letter to the Staff examiner at least five business days in advance of the date you seek to go effective. Please remove all brackets and fill in all outstanding information prior to the 485(b) filing with the SEC. The Staff notes that the Trust and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Please note that where a comment is made in one section of the Registration Statement, such comment is applicable to similar disclosures appearing elsewhere in the Registration Statement.
Response 1. We respectfully acknowledge your comment.
PROSPECTUS
Comment 2. In the “Summary Information—Portfolio Turnover” section, please add, if true, that due to changes in the Fund’s principal investment strategies, following the date those changes will be implemented, the Fund may experience a higher level of portfolio turnover in the current fiscal year than in previous fiscal years. Also, if there will be significant portfolio turnover due to the change, please add a portfolio turnover risk in the “Summary Information—Principal Risks of Investing in the Fund” section of the prospectus. Please also add appropriate disclosure regarding the anticipated variation in the Fund’s turnover rate, pursuant to Item 16(e) of the Statement of Additional Information (“SAI”).
Response 2. The disclosure has been revised accordingly. We note that the “Summary Information—Principal Risks of Investing in the Fund” section of the prospectus also included “High Portfolio Turnover Risk.”
Comment 3. With respect to the 80% policy described in the “Summary Information—Principal Investment Strategies” section, please confirm and state in the disclosure, if true, that the Fund’s Index is 100% comprised of Chinese bonds with maturity of 0-10 years, per the Index’s name. The Staff has reviewed the Index guide and could not determine from the Index guide if the Index is 100% comprised of bonds with maturity of 0-10 years. For example, in one section, the Index guide states the minimum maturity is less than 10 years, but in another section, it is stated that the Index excludes bonds with maturities greater than 30 years. As such, the Staff is not certain if the Index is 100% invested in bonds with maturity of 0-10 years.
Response 3. We hereby confirm that the Index is entirely comprised of bonds with maturity of 0-10 years. The disclosure has been revised accordingly.
Comment 4. With respect to the “Summary Information—Principal Investment Strategies” section, the Staff notes the explanatory note describing Chinese credit issuers has been deleted. If applicable, please provide a similar explanatory note for the types of issuers that are Chinese credit issuers under the new Index either in Item 4 or Item 9.
Response 4. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 5. With respect to the third sentence of the “Summary Information—Principal Investment Strategies” section, please confirm that all three types of bonds in the Index must have an investment grade rating. The current disclosure is not clear whether the investment grade rating applies to all three types of bonds, as opposed to only credit RMB Bonds. The Staff also notes it should apply to the bonds. As written, the disclosure states that “Credit RMB Bonds or the issuer” must have an investment grade rating. Please clarify what you mean by “or the issuer.”
Response 5. We confirm that, in accordance with current Index rules, the rating criteria applies only to credit bonds. The disclosure has been revised accordingly.
Comment 6. With respect to the sentence of the “Summary Information—Principal Investment Strategies” section stating, “[t]hese RMB Bonds are made available to domestic PRC investors and certain foreign investors, including via the Bond Connect program,” please tailor the disclosure to the Fund’s principal strategy, which is to invest primarily in bonds through Bond Connect. The phrasing of “including via the” indicates that there are other principal means of making the bonds available to investors.
Response 6. The disclosure has been revised accordingly.
Comment 7. Please supplementally explain or confirm why the language about Renminbi Qualified Foreign Institutional Investor (“RQFII”) and Qualified Foreign Institutional Investor (“QFII”) have been removed.
Response 7. The disclosure regarding the RQFII and QFII programs has been removed because the regulatory regime in China has changed and the Fund no longer expects to invest in Chinese bonds through these means.
Comment 8. With respect to the second sentence of the last paragraph under the “Summary Information—Principal Investment Strategies” section, please change “may concentrate” to “will concentrate.”
Response 8. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate. As disclosed under the “Index Tracking Risk” disclosure, the Fund may not be able to replicate the concentration of the Index for various reasons, such as regulatory restrictions or a lack of liquidity for the Index constituents. In addition, the Fund's use of a representative sampling approach may also cause the Fund to not be able to replicate the concentration of the Index.
Comment 9. The Staff notes that within the “Summary Information—Principal Risks of Investing in the Fund” section, there is considerable overlap in the “Emerging Market Issuers Risk” and certain China-specific risk factors. Please consider reducing some of the overlap, where possible, to make it clearer for investors and avoid duplicative disclosure.
Response 9. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 10. With respect to the first sentence of the second paragraph under the “Summary Information—Principal Risks of Investing in the Fund—RMB Bonds Risk” section, please revise the disclosure to make it consistent with earlier disclosure that the bonds must have an investment grade rating, or explain why this is different.
Response 10. The disclosure has been revised accordingly. The Index methodology does not rely on local credit ratings. The Index includes higher quality bonds that are subject to a 10-year cap on maturity, greater minimum size requirements, and relies on Standard & Poor's and Moody's Investor Services credit ratings. In addition to eliminating the referenced language the Staff noted, the Credit Risk paragraph, which is no longer applicable, has also been removed.
Comment 11. Please tailor the disclosure under “Summary Information—Principal Risks of Investing in the Fund—Bond Connect and the CIBM Direct Access Program Risk” by deleting the reference to programs other than Bond Connect (i.e., “CIBM Direct Access”), if they are not part of the Fund’s principal investment strategies, given that the disclosure in the “Summary Information—Principal Investment Strategies” states that the “Fund seeks to achieve its investment objective by primarily investing in RMB Bonds through Bond Connect.”
Response 11. The disclosure has been revised accordingly.
Comment 12. With respect to the first sentence of the “Summary Information—Principal Risks of Investing in the Fund—Subordinated Obligations Risk” section, please add the disclosure in this sentence to “Summary Information—Principal Investment Strategies” section, if it is a principal risk.
Response 12. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 13. With respect to “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk,” given that the Fund has an investment strategy to track an index with significant exposure to Chinese companies, please provide disclosure with respect to the following risks associated with this strategy or explain why such disclosure would not be appropriate: (i) the potential for errors in index data, index computation and/or index construction if information on Chinese companies or bonds is unreliable or outdated, or if less information about such companies or bonds is publicly available due to differences in regulatory, accounting, auditing, and financial recordkeeping standards; (ii) the potential significance of such errors on the Fund’s performance; (iii) the limitations on a fund’s adviser’s ability to oversee the index provider’s due diligence process over index data prior to its use in index computation, construction and/or rebalancing; and (iv) the rights and remedies associated with investments in a fund that tracks an index comprised of Chinese securities may be different than a fund that tracks domestic securities.
Response 13. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 14. With respect to the second sentence of the “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk” relating to derivatives transactions, please tailor the disclosure to the Fund’s principal investment strategy. If derivatives transactions are not applicable as principal investment strategy and risk, please delete this language, or if they are, please add description about the derivatives strategy in Item 4 and Item 9.
Response 14. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 15. With respect to the second paragraph of the “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk,” the Staff notes the disclosure stating, “[m]arket disruptions and regulatory restrictions could have an adverse effect on the Fund’s ability to adjust its exposure to the required levels in order to track the Index.” However, the Staff nevertheless requests disclosure regarding tracking error related to tracking an index comprised of Chinese companies be made more explicit in the “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk” section.
Response 15. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 16. With respect to the “Summary Information—Principal Risks of Investing in the Fund—Index-Related Concentration Risk” disclosure, please change “may be concentrated” to “will be concentrated.”
Response 16. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 17. In light of the inclusion of the “Summary Information—Principal Risks of Investing in the Fund—High Portfolio Turnover Risk” section, please add high portfolio turnover to the principal investment strategy disclosure as well. In addition, please revise the disclosure in response to Comment 2 above to reflect any increase in portfolio turnover due to a change in the Index.
Response 17. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 18. With respect to the “Additional Information About the Fund’s Investment Strategies and Risk—Principal Investment Strategies” section, please carry forward all comments given on the “Summary Information—Principal Investment Strategies” section.
Response 18. We respectfully acknowledge your comment and confirm that to the extent revisions are made to the “Summary Information—Principal Investment Strategies” section, corresponding revisions to the Additional Information About the Fund’s Investment Strategies and Risk—Principal Investment Strategies” section have been made.
Comment 19. With respect to the “Additional Information About the Fund’s Investment Strategies and Risks” section, according to Form N-1A, the disclosure provided pursuant to Items 4(a) and 4(b) should be a summary of the disclosure provided pursuant to Items 9(b) and 9(c). Please accordingly describe the Fund’s principal investment strategies and principal risks in the disclosure pursuant to Items 9(b) and 9(c) that were summarized in the disclosure pursuant Items 4(a) and 4(b) to follow the layered disclosure regime contemplated by form N-1A.
Response 19. We respectfully acknowledge your comment; however, we believe that the referenced disclosure is appropriate and consistent with the requirements of Form N-1A.
Comment 20. With respect to the “Additional Information About the Fund’s Investment Strategies and Risk—Principal Investment Strategies” section, please disclose how the Adviser determines when to sell, if it is any different than the strategy of replicating the Index.
Response 20. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 21. With respect to the “Additional Information About the Fund’s Investment Strategies and Risks—Fundamental and Non-Fundamental Policies” section, please disclose the Fund’s concentration policy and diversification status.
Response 21. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 22. With respect to the “Additional Information About the Fund’s Investment Strategies and Risk—Risks of Investing in the Fund—Bond Connect and the CIBM Direct Access Program Risk—Investments and Repatriations Restrictions” section, please delete the reference to “warrants and open- and closed-end investment companies” if that is not a principal investment strategy of the Fund, or if it is, please add it to the strategy disclosure.
Response 22. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 23. The Staff notes that the last paragraph of the “Additional Information About the Fund’s Investment Strategies and Risk—Risks of Investing in the Fund—Bond Connect and the CIBM Direct Access Program Risk—Investment and Repatriation Restrictions” section is the type of disclosure that should be included as part of a more tailored tracking error risk factor, per Comment 15 above.
Response 23. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 24. With respect to the disclosure in the fourth paragraph of the “Additional Information About the Fund’s Investment Strategies and Risk—Risks of Investing in the Fund—Index Tracking Risk” section regarding “depositary receipts or other derivative instruments,” please tailor the disclosure to track the Fund’s principal investment strategy, or if they are already tailored, please add corresponding disclosure to the principal investment strategies section.
Response 24. We respectfully acknowledge your co
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CORRESP
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Document
May 23, 2024
U.S. Securities and Exchange Commission
Judiciary Plaza
100 F Street, N.E.
Washington, D.C. 20549
Attn: Emily Rowland, Division of Investment Management
Re: VanEck ETF Trust (the “Trust”)
(File Nos. 333-123257 and 811-10325)
Dear Ms. Rowland:
We are in receipt of your comments regarding the registration statement on Form N-1A (the “Registration Statement”) for the Trust with respect to VanEck China Bond ETF (the “Fund”), a series of the Trust, filed with the Securities and Exchange Commission (the “SEC”) on March 25, 2024. The Trust has considered your comments and has authorized us to make the responses and changes discussed below to the Registration Statement on its behalf. Below, we describe the changes that have been or will be incorporated into the Fund’s Registration Statement in response to the Staff of the SEC’s (the “Staff”) comments and provide any responses to or any supplemental explanations of such comments, as requested. Capitalized terms used in our responses have the meanings attributed to such terms in the Registration Statement, unless otherwise noted.
GENERAL
Comment 1. Please respond to all comments in a letter filed as a correspondence on EDGAR and email a courtesy copy of the letter to the Staff examiner at least five business days in advance of the date you seek to go effective. Please remove all brackets and fill in all outstanding information prior to the 485(b) filing with the SEC. The Staff notes that the Trust and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff. Please note that where a comment is made in one section of the Registration Statement, such comment is applicable to similar disclosures appearing elsewhere in the Registration Statement.
Response 1. We respectfully acknowledge your comment.
PROSPECTUS
Comment 2. In the “Summary Information—Portfolio Turnover” section, please add, if true, that due to changes in the Fund’s principal investment strategies, following the date those changes will be implemented, the Fund may experience a higher level of portfolio turnover in the current fiscal year than in previous fiscal years. Also, if there will be significant portfolio turnover due to the change, please add a portfolio turnover risk in the “Summary Information—Principal Risks of Investing in the Fund” section of the prospectus. Please also add appropriate disclosure regarding the anticipated variation in the Fund’s turnover rate, pursuant to Item 16(e) of the Statement of Additional Information (“SAI”).
Response 2. The disclosure has been revised accordingly. We note that the “Summary Information—Principal Risks of Investing in the Fund” section of the prospectus also included “High Portfolio Turnover Risk.”
Comment 3. With respect to the 80% policy described in the “Summary Information—Principal Investment Strategies” section, please confirm and state in the disclosure, if true, that the Fund’s Index is 100% comprised of Chinese bonds with maturity of 0-10 years, per the Index’s name. The Staff has reviewed the Index guide and could not determine from the Index guide if the Index is 100% comprised of bonds with maturity of 0-10 years. For example, in one section, the Index guide states the minimum maturity is less than 10 years, but in another section, it is stated that the Index excludes bonds with maturities greater than 30 years. As such, the Staff is not certain if the Index is 100% invested in bonds with maturity of 0-10 years.
Response 3. We hereby confirm that the Index is entirely comprised of bonds with maturity of 0-10 years. The disclosure has been revised accordingly.
Comment 4. With respect to the “Summary Information—Principal Investment Strategies” section, the Staff notes the explanatory note describing Chinese credit issuers has been deleted. If applicable, please provide a similar explanatory note for the types of issuers that are Chinese credit issuers under the new Index either in Item 4 or Item 9.
Response 4. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 5. With respect to the third sentence of the “Summary Information—Principal Investment Strategies” section, please confirm that all three types of bonds in the Index must have an investment grade rating. The current disclosure is not clear whether the investment grade rating applies to all three types of bonds, as opposed to only credit RMB Bonds. The Staff also notes it should apply to the bonds. As written, the disclosure states that “Credit RMB Bonds or the issuer” must have an investment grade rating. Please clarify what you mean by “or the issuer.”
Response 5. We confirm that, in accordance with current Index rules, the rating criteria applies only to credit bonds. The disclosure has been revised accordingly.
Comment 6. With respect to the sentence of the “Summary Information—Principal Investment Strategies” section stating, “[t]hese RMB Bonds are made available to domestic PRC investors and certain foreign investors, including via the Bond Connect program,” please tailor the disclosure to the Fund’s principal strategy, which is to invest primarily in bonds through Bond Connect. The phrasing of “including via the” indicates that there are other principal means of making the bonds available to investors.
Response 6. The disclosure has been revised accordingly.
Comment 7. Please supplementally explain or confirm why the language about Renminbi Qualified Foreign Institutional Investor (“RQFII”) and Qualified Foreign Institutional Investor (“QFII”) have been removed.
Response 7. The disclosure regarding the RQFII and QFII programs has been removed because the regulatory regime in China has changed and the Fund no longer expects to invest in Chinese bonds through these means.
Comment 8. With respect to the second sentence of the last paragraph under the “Summary Information—Principal Investment Strategies” section, please change “may concentrate” to “will concentrate.”
Response 8. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate. As disclosed under the “Index Tracking Risk” disclosure, the Fund may not be able to replicate the concentration of the Index for various reasons, such as regulatory restrictions or a lack of liquidity for the Index constituents. In addition, the Fund's use of a representative sampling approach may also cause the Fund to not be able to replicate the concentration of the Index.
Comment 9. The Staff notes that within the “Summary Information—Principal Risks of Investing in the Fund” section, there is considerable overlap in the “Emerging Market Issuers Risk” and certain China-specific risk factors. Please consider reducing some of the overlap, where possible, to make it clearer for investors and avoid duplicative disclosure.
Response 9. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 10. With respect to the first sentence of the second paragraph under the “Summary Information—Principal Risks of Investing in the Fund—RMB Bonds Risk” section, please revise the disclosure to make it consistent with earlier disclosure that the bonds must have an investment grade rating, or explain why this is different.
Response 10. The disclosure has been revised accordingly. The Index methodology does not rely on local credit ratings. The Index includes higher quality bonds that are subject to a 10-year cap on maturity, greater minimum size requirements, and relies on Standard & Poor's and Moody's Investor Services credit ratings. In addition to eliminating the referenced language the Staff noted, the Credit Risk paragraph, which is no longer applicable, has also been removed.
Comment 11. Please tailor the disclosure under “Summary Information—Principal Risks of Investing in the Fund—Bond Connect and the CIBM Direct Access Program Risk” by deleting the reference to programs other than Bond Connect (i.e., “CIBM Direct Access”), if they are not part of the Fund’s principal investment strategies, given that the disclosure in the “Summary Information—Principal Investment Strategies” states that the “Fund seeks to achieve its investment objective by primarily investing in RMB Bonds through Bond Connect.”
Response 11. The disclosure has been revised accordingly.
Comment 12. With respect to the first sentence of the “Summary Information—Principal Risks of Investing in the Fund—Subordinated Obligations Risk” section, please add the disclosure in this sentence to “Summary Information—Principal Investment Strategies” section, if it is a principal risk.
Response 12. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 13. With respect to “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk,” given that the Fund has an investment strategy to track an index with significant exposure to Chinese companies, please provide disclosure with respect to the following risks associated with this strategy or explain why such disclosure would not be appropriate: (i) the potential for errors in index data, index computation and/or index construction if information on Chinese companies or bonds is unreliable or outdated, or if less information about such companies or bonds is publicly available due to differences in regulatory, accounting, auditing, and financial recordkeeping standards; (ii) the potential significance of such errors on the Fund’s performance; (iii) the limitations on a fund’s adviser’s ability to oversee the index provider’s due diligence process over index data prior to its use in index computation, construction and/or rebalancing; and (iv) the rights and remedies associated with investments in a fund that tracks an index comprised of Chinese securities may be different than a fund that tracks domestic securities.
Response 13. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 14. With respect to the second sentence of the “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk” relating to derivatives transactions, please tailor the disclosure to the Fund’s principal investment strategy. If derivatives transactions are not applicable as principal investment strategy and risk, please delete this language, or if they are, please add description about the derivatives strategy in Item 4 and Item 9.
Response 14. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 15. With respect to the second paragraph of the “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk,” the Staff notes the disclosure stating, “[m]arket disruptions and regulatory restrictions could have an adverse effect on the Fund’s ability to adjust its exposure to the required levels in order to track the Index.” However, the Staff nevertheless requests disclosure regarding tracking error related to tracking an index comprised of Chinese companies be made more explicit in the “Summary Information—Principal Risks of Investing in the Fund—Index Tracking Risk” section.
Response 15. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 16. With respect to the “Summary Information—Principal Risks of Investing in the Fund—Index-Related Concentration Risk” disclosure, please change “may be concentrated” to “will be concentrated.”
Response 16. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 17. In light of the inclusion of the “Summary Information—Principal Risks of Investing in the Fund—High Portfolio Turnover Risk” section, please add high portfolio turnover to the principal investment strategy disclosure as well. In addition, please revise the disclosure in response to Comment 2 above to reflect any increase in portfolio turnover due to a change in the Index.
Response 17. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 18. With respect to the “Additional Information About the Fund’s Investment Strategies and Risk—Principal Investment Strategies” section, please carry forward all comments given on the “Summary Information—Principal Investment Strategies” section.
Response 18. We respectfully acknowledge your comment and confirm that to the extent revisions are made to the “Summary Information—Principal Investment Strategies” section, corresponding revisions to the Additional Information About the Fund’s Investment Strategies and Risk—Principal Investment Strategies” section have been made.
Comment 19. With respect to the “Additional Information About the Fund’s Investment Strategies and Risks” section, according to Form N-1A, the disclosure provided pursuant to Items 4(a) and 4(b) should be a summary of the disclosure provided pursuant to Items 9(b) and 9(c). Please accordingly describe the Fund’s principal investment strategies and principal risks in the disclosure pursuant to Items 9(b) and 9(c) that were summarized in the disclosure pursuant Items 4(a) and 4(b) to follow the layered disclosure regime contemplated by form N-1A.
Response 19. We respectfully acknowledge your comment; however, we believe that the referenced disclosure is appropriate and consistent with the requirements of Form N-1A.
Comment 20. With respect to the “Additional Information About the Fund’s Investment Strategies and Risk—Principal Investment Strategies” section, please disclose how the Adviser determines when to sell, if it is any different than the strategy of replicating the Index.
Response 20. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 21. With respect to the “Additional Information About the Fund’s Investment Strategies and Risks—Fundamental and Non-Fundamental Policies” section, please disclose the Fund’s concentration policy and diversification status.
Response 21. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 22. With respect to the “Additional Information About the Fund’s Investment Strategies and Risk—Risks of Investing in the Fund—Bond Connect and the CIBM Direct Access Program Risk—Investments and Repatriations Restrictions” section, please delete the reference to “warrants and open- and closed-end investment companies” if that is not a principal investment strategy of the Fund, or if it is, please add it to the strategy disclosure.
Response 22. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 23. The Staff notes that the last paragraph of the “Additional Information About the Fund’s Investment Strategies and Risk—Risks of Investing in the Fund—Bond Connect and the CIBM Direct Access Program Risk—Investment and Repatriation Restrictions” section is the type of disclosure that should be included as part of a more tailored tracking error risk factor, per Comment 15 above.
Response 23. We respectfully acknowledge your comment; however, we believe the referenced disclosure is appropriate.
Comment 24. With respect to the disclosure in the fourth paragraph of the “Additional Information About the Fund’s Investment Strategies and Risk—Risks of Investing in the Fund—Index Tracking Risk” section regarding “depositary receipts or other derivative instruments,” please tailor the disclosure to track the Fund’s principal investment strategy, or if they are already tailored, please add corresponding disclosure to the principal investment strategies section.
Response 24. We respectfully acknowledge your co