Correspondence 0001104659-22-122732 from Hartford Funds Exchange-Traded Trust (CIK 0001501825)
Hartford Funds Exchange-Traded Trust (CIK 0001501825)
Date: Nov. 29, 2022 · CIK: 0001501825 · Accession: 0001104659-22-122732
AI Filing Summary & Sentiment
File numbers found in text: 333-215165, 811-23222
Referenced dates: November 18, 2022, November 18, 2022
Letter
VIA EDGAR CORRESPONDENCE Division of Investment Management 100 F Street, NE Washington, D.C. 20549-4644 Re: Hartford Funds Exchange-Traded Trust (the “Registrant”) (SEC File Nos. 333-215165 and 811-23222)
Dear Mr. O’Connell and Ms. Brutlag:
We are writing in response to a follow-up comment you provided telephonically to Kyle Whiteman and me on November 23, 2022 with respect to our letter dated November 18, 2022 responding to the Staff’s comments to the Registrant’s Post-Effective Amendment No. 39, filed on September 23, 2022, relating to Hartford Sustainable Income ETF (the “Fund”), an existing series of the Registrant. On behalf of the Registrant, we have reproduced your comment below and provided the Fund’s response immediately thereafter. Capitalized terms have the meanings attributed to such terms in the Post-Effective Amendment.
Comment: With respect to comment 6(ii) and the Registrant’s response thereto as set forth in your letter dated November 18, 2022, the Staff believes that the Composite’s investment objectives, policies or strategies are not “substantially similar” to those of the Fund because, unlike the Fund, the Composite did not have a sustainability focus for the entire performance period shown. Accordingly, please delete the Prior Performance of Related Accounts for any periods during which the Composite did not have a sustainability focus.
Response: The Registrant respectfully disagrees with the Staff’s comment that the Composite and the Fund do not have “substantially similar” investment objectives, policies or strategies for the reasons set forth in our response dated November 18, 2022. However, the Registrant has deleted the Prior Performance of Related Accounts from the Fund’s post-effective amendment and reserves the right to discuss this comment further with the Staff.
Should you have any questions, please feel free to contact me at (202) 261-3464.
Sincerely,
/s/ Adam T. Teufel
Show Raw Text
CORRESP
1
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
November 29, 2022
VIA EDGAR CORRESPONDENCE
Keith O’Connell
Samantha Brutlag
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549-4644
Re: Hartford Funds Exchange-Traded Trust (the “Registrant”) (SEC File Nos.
333-215165 and 811-23222)
Dear Mr. O’Connell and Ms. Brutlag:
We are writing in response
to a follow-up comment you provided telephonically to Kyle Whiteman and me on November 23, 2022 with respect to our letter dated November
18, 2022 responding to the Staff’s comments to the Registrant’s Post-Effective Amendment No. 39, filed on September 23, 2022,
relating to Hartford Sustainable Income ETF (the “Fund”), an existing series of the Registrant. On behalf of the Registrant,
we have reproduced your comment below and provided the Fund’s response immediately thereafter. Capitalized terms have the meanings
attributed to such terms in the Post-Effective Amendment.
Comment: With respect to comment 6(ii) and the Registrant’s response thereto as set
forth in your letter dated November 18, 2022, the Staff believes that the Composite’s investment objectives, policies or strategies
are not “substantially similar” to those of the Fund because, unlike the Fund, the Composite did not have a sustainability
focus for the entire performance period shown. Accordingly, please delete the Prior Performance of Related Accounts for any periods during
which the Composite did not have a sustainability focus.
Response: The Registrant respectfully disagrees with the Staff’s comment that the Composite
and the Fund do not have “substantially similar” investment objectives, policies or strategies for the reasons set forth in
our response dated November 18, 2022. However, the Registrant has deleted the Prior Performance of Related Accounts from the Fund’s
post-effective amendment and reserves the right to discuss this comment further with the Staff.
Should you have any
questions, please feel free to contact me at (202) 261-3464.
Sincerely,
/s/ Adam T. Teufel
Adam T. Teufel
cc: Alice A. Pellegrino
John V. O’Hanlon