Correspondence 0001398344-23-015154 from ALPS ETF Trust (CIK 0001414040)
ALPS ETF Trust (CIK 0001414040)
Date: Aug. 18, 2023 · CIK: 0001414040 · Accession: 0001398344-23-015154
AI Filing Summary & Sentiment
File numbers found in text: 333-148826, 811-22175
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management 100 F Street, NE Washington, D.C. 20549-4644 Re: ALPS ETF Trust (the “Registrant”) (SEC File Nos. 333-148826 and 811-22175)
Dear Mr. Foor:
We are writing in response to comments you provided telephonically to Kyle Whiteman and me on August 16, 2023 with respect to the Registrant’s Post-Effective Amendment No. 322, filed as of June 26, 2023, relating to ALPS Active REIT ETF (the “Fund”), an existing series of the Registrant. On behalf of the Registrant, we have reproduced your comments below and provided the Registrant’s responses immediately thereafter. Capitalized terms have the meanings attributed to such terms in Post-Effective Amendment No. 322.
1. Comment: The prospectus states: “Out of the unitary management fee, the Adviser pays substantially all expenses of the Fund, including the cost of sub-advisory, transfer agency, custody, fund administration, legal, audit, trustees and other services, except for interest expenses, distribution fees or expenses, brokerage expenses, taxes and extraordinary expenses such as litigation and other expenses not incurred in the ordinary course of the Fund’s business.” To the extent the Fund may invest in underlying funds, consider revising this sentence to address whether the Adviser or the Fund bears the Fund’s Acquired Fund Fees and Expenses (“AFFE”), if any.
Response: Comment acknowledged. The Fund does not currently bear AFFE, therefore the Registrant does not believe revised disclosure is necessary at this time.
Should you have any questions, please feel free to contact me at (202) 261-3464.
Sincerely,
/s/ Adam T. Teufel
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CORRESP
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filename1.htm
1900 K Street, NW
Washington, DC 20006-1110
+1 202 261 3300 Main
+1 202 261 3333 Fax
www.dechert.com
ADAM T. TEUFEL
adam.teufel@dechert.com
+1 202 261 3464 Direct
+1 202 261 3164 Fax
August 18, 2023
VIA EDGAR CORRESPONDENCE
Jeff Foor
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549-4644
Re: ALPS ETF Trust (the “Registrant”) (SEC File Nos. 333-148826 and 811-22175)
Dear Mr. Foor:
We are writing in response to
comments you provided telephonically to Kyle Whiteman and me on August 16, 2023 with respect to the Registrant’s Post-Effective
Amendment No. 322, filed as of June 26, 2023, relating to ALPS Active REIT ETF (the “Fund”), an existing series of the Registrant.
On behalf of the Registrant, we have reproduced your comments below and provided the Registrant’s responses immediately thereafter.
Capitalized terms have the meanings attributed to such terms in Post-Effective Amendment No. 322.
1.
Comment: The prospectus states: “Out of the unitary management
fee, the Adviser pays substantially all expenses of the Fund, including the cost of sub-advisory,
transfer agency, custody, fund administration, legal, audit, trustees and other services,
except for interest expenses, distribution fees or expenses, brokerage expenses, taxes and
extraordinary expenses such as litigation and other expenses not incurred in the ordinary
course of the Fund’s business.” To the extent the Fund may invest in underlying
funds, consider revising this sentence to address whether the Adviser or the Fund bears the
Fund’s Acquired Fund Fees and Expenses (“AFFE”), if any.
Response: Comment acknowledged. The Fund does not currently bear AFFE, therefore the Registrant does not believe
revised disclosure is necessary at this time.
Should you have any questions, please
feel free to contact me at (202) 261-3464.
Sincerely,
/s/ Adam T. Teufel
Adam T. Teufel
cc: Rick Noyes
Michael Lawlor