Correspondence 0001484018-25-000091 from Spinnaker ETF Series (CIK 0001484018)
Spinnaker ETF Series (CIK 0001484018)
Date: Aug. 15, 2025 · CIK: 0001484018 · Accession: 0001484018-25-000091
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-215942, 811-22398
Letter
August 15, 2025 VIA EDGAR ========== Mark Cowan Division of Investment Management Securities and Exchange Commission Filing Desk 100 F Street, N.E. Washington, DC 20549 Spinnaker ETF Series; File Nos. 333-215942 and 811-22398
RE:
Dear Mr. Cowan, On June 20, 2025, Spinnaker ETF Series (the “Trust” or the “Registrant”) filed a registration statement under the Securities Act of 1933 on Form N-1A (the “Registration Statement”) with respect to the Select STOXX Europe Aerospace & Defense ETF (the “Fund”). On July 25, 2025, you provided oral comments to the Registration Statement. Please find below a summary of those comments and the Registrant's responses, which the Registrant has authorized us to make on behalf of the Registrant. Prospectus : Comment 1 . In “Principal Risks of Investing in the Fund – Derivates Risk”, it references forward contracts and the use of swaps for hedging purposes. Please revise the strategy to include a discussion of the use of forward contracts and swaps for hedging purposes or remove the references to those items in the risk. Response . The Registrant has revised the risk to remove reference to the items noted.
* * *
If you have any questions or comments, please contact the undersigned at 404.736.7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
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CORRESP 1 filename1.htm DLA Piper LLP (US) One Atlantic Center 1201 West Peachtree Street Suite 2900 Atlanta, Georgia 30309-3449 www.dlapiper.com Tanya L. Boyle tanya.boyle@us.dlapiper.com T 404.736.7863 F 404.682.7863 August 15, 2025 VIA EDGAR ========== Mark Cowan Division of Investment Management Securities and Exchange Commission Filing Desk 100 F Street, N.E. Washington, DC 20549 RE: Spinnaker ETF Series; File Nos. 333-215942 and 811-22398 Dear Mr. Cowan, On June 20, 2025, Spinnaker ETF Series (the “Trust” or the “Registrant”) filed a registration statement under the Securities Act of 1933 on Form N-1A (the “Registration Statement”) with respect to the Select STOXX Europe Aerospace & Defense ETF (the “Fund”). On July 25, 2025, you provided oral comments to the Registration Statement. Please find below a summary of those comments and the Registrant's responses, which the Registrant has authorized us to make on behalf of the Registrant. Prospectus : Comment 1 . In “Principal Risks of Investing in the Fund – Derivates Risk”, it references forward contracts and the use of swaps for hedging purposes. Please revise the strategy to include a discussion of the use of forward contracts and swaps for hedging purposes or remove the references to those items in the risk. Response . The Registrant has revised the risk to remove reference to the items noted. * * * If you have any questions or comments, please contact the undersigned at 404.736.7863. Thank you in advance for your consideration. Sincerely, /s/ Tanya L. Boyle Tanya L. Boyle