SEC Company Response from EXCHANGE TRADED CONCEPTS TRUST (CIK 0001452937) — May 22, 2020
EXCHANGE TRADED CONCEPTS TRUST (CIK 0001452937)
Date: May 22, 2020 · CIK: 0001452937 · Accession: 0001615774-20-006176
AI Filing Summary & Sentiment
File numbers found in text: 333-156529, 811-22263
Letter
VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Exchange Traded Concepts Trust (File Nos. 333-156529 and 811-22263)
Dear Mr. Grzeskiewicz:
This letter responds to comments relating to Post-Effective Amendment No. 284 (“PEA No. 284”) to the registration statement on Form N-1A of Exchange Traded Concepts Trust (the “Registrant”). PEA No. 284 was filed on April 8, 2020 for the purpose of registering shares of the North Shore Dual Share Class ETF (the “Fund”). For ease of reference, set forth below are your comments followed by the Registrant’s responses. Unless otherwise noted, capitalized terms have the same meaning as those contained in PEA No. 284.
1. Comment. Please provide a completed fee table and expense example for the Fund.
Response. Registrant represents that the requested information has been provided under separate cover.
2. Comment. Please consider adding the disclosure about COVID-19 that is currently in the Statement of Additional Information to the Item 9 disclosure in the prospectus.
Response. Registrant responds that it has determined to maintain the disclosure as filed.
3. Comment. If there are any other industries or sectors that may be expected to reach 25% of assets, please consider adding disclosure proactively with respect to those industries or sectors.
Response. Registrant responds that it has determined to add disclosure regarding the communication services sector.
* * * * *
Morgan, Lewis & Bockius llp
1111 Pennsylvania Avenue, NW
Washington, DC 20004 +1.202.739.3000
United States +1.202.739.3001
May 22, 2020
Page 2
If you have questions or comments, please do not hesitate to contact me at 202.373.6091.
Sincerely,
/s/ Magda El Guindi-Rosenbaum
Show Raw Text
CORRESP
1
filename1.htm
Magda El Guindi-Rosenbaum
+1.202.373.6091
mer@morganlewis.com
VIA EDGAR
May 22, 2020
John Grzeskiewicz, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Exchange Traded Concepts Trust (File Nos. 333-156529
and 811-22263)
Dear Mr. Grzeskiewicz:
This letter responds to comments relating to Post-Effective
Amendment No. 284 (“PEA No. 284”) to the registration statement on Form N-1A of Exchange Traded Concepts Trust (the
“Registrant”). PEA No. 284 was filed on April 8, 2020 for the purpose of registering shares of the North Shore Dual
Share Class ETF (the “Fund”). For ease of reference, set forth below are your comments followed by the Registrant’s
responses. Unless otherwise noted, capitalized terms have the same meaning as those contained in PEA No. 284.
1. Comment. Please provide a completed fee table and expense example for the Fund.
Response. Registrant represents that
the requested information has been provided under separate cover.
2. Comment. Please consider adding the disclosure about COVID-19 that is currently in the Statement of Additional
Information to the Item 9 disclosure in the prospectus.
Response. Registrant responds that it
has determined to maintain the disclosure as filed.
3. Comment. If there are any other industries or sectors that may be expected to reach 25% of assets, please consider
adding disclosure proactively with respect to those industries or sectors.
Response. Registrant responds that it
has determined to add disclosure regarding the communication services sector.
* * * * *
Morgan, Lewis & Bockius llp
1111 Pennsylvania Avenue, NW
Washington, DC 20004
+1.202.739.3000
United States
+1.202.739.3001
May 22, 2020
Page 2
If you have questions or comments, please do not hesitate
to contact me at 202.373.6091.
Sincerely,
/s/ Magda El Guindi-Rosenbaum
Magda El Guindi-Rosenbaum