SEC Company Response from DBX ETF TRUST (CIK 0001503123) — Jan 6, 2020
DBX ETF TRUST (CIK 0001503123)
Date: Jan. 6, 2020 · CIK: 0001503123 · Accession: 0000088053-20-000019
AI Filing Summary & Sentiment
File numbers found in text: 333-170122, 811-22487
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Attn: Raymond Be Re: Post-Effective Amendment No. 459 to the Registration Statement on Form N-1A of Xtrackers MSCI Kokusai Equity ETF (the “Fund”), a series of DBX ETF Trust (the “Trust”) (Reg. Nos. 333-170122; 811-22487)
Dear Mr. Be,
This letter is being submitted on behalf of the Fund in response to comments of the Staff of the Securities and Exchange Commission (the “SEC”) regarding the above-referenced Post-Effective Amendment (the “Amendment”), whose comments were received via telephone on December 16, 2019. The Amendment was filed on behalf of the Fund on October 28, 2019, and has an effective date of January 13, 2020.
The Staff’s comments are restated below, followed by the Fund’s responses.
1. Comment: Please file responses to these comments and e-mail any changed pages to the SEC at least five (5) days prior to the effective date.
Response: On the same day that the Trust files this correspondence we will e-mail changed pages to the following e-mail address: BERA@sec.gov.
2. Comment: “Principal Investment Strategies” – page 2. Explain how securities are selected to be part of the underlying index. Additionally, explain how the index is weighted.
Response: The following disclosure has been added to the “Principal Investment Strategies” section of the Fund’s prospectus: “The Underlying Index is designed to cover approximately 85% of the free float-adjusted market capitalization of each country represented in the index. The index methodology selects the countries classified as developed, excludes Japan, and then applies certain liquidity screens.”
3. Comment: “Financial services sector risk” – page 10. Consider updating the “2007-2008” reference to the financial crisis.
Response: We recently re-evaluated this risk disclosure and modified it to note that the effects of the 2007-2008 financial crisis may persist indefinitely. The Amendment included this updated disclosure. We believe that the effects of the financial crisis continue to influence the financial markets and, at this time, we believe the disclosure is appropriate.
4. Comment: “Derivatives risk” – page 13. If derivatives are a principal strategy, please relocate derivatives disclosure to the summary prospectus.
Response: The portfolio managers do not intend to use derivatives as a principal strategy.
If you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-2565.
Sincerely yours,
/s/Caroline Pearson
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DWS Investment Management Americas, Inc.
One International Place
Boston, MA 02110
January 6, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Raymond Be
Re:
Post-Effective Amendment No. 459 to the Registration Statement on Form N-1A of Xtrackers MSCI Kokusai Equity ETF (the “Fund”), a series of DBX ETF Trust (the “Trust”) (Reg. Nos. 333-170122; 811-22487)
Dear Mr. Be,
This letter is being submitted on behalf of
the Fund in response to comments of the Staff of the Securities and Exchange Commission (the “SEC”) regarding the above-referenced
Post-Effective Amendment (the “Amendment”), whose comments were received via telephone on December 16, 2019. The Amendment
was filed on behalf of the Fund on October 28, 2019, and has an effective date of January 13, 2020.
The Staff’s comments are restated below,
followed by the Fund’s responses.
1. Comment: Please file responses to these comments and e-mail any changed pages to the SEC at least five (5) days prior
to the effective date.
Response: On the same day that the Trust files
this correspondence we will e-mail changed pages to the following e-mail address: BERA@sec.gov.
2. Comment: “Principal Investment Strategies” – page 2. Explain how securities are selected to be part
of the underlying index. Additionally, explain how the index is weighted.
Response: The following disclosure has been added
to the “Principal Investment Strategies” section of the Fund’s prospectus: “The Underlying Index is designed
to cover approximately 85% of the free float-adjusted market capitalization of each country represented in the index. The index
methodology selects the countries classified as developed, excludes Japan, and then applies certain liquidity screens.”
3. Comment: “Financial services sector risk” – page 10. Consider updating the “2007-2008”
reference to the financial crisis.
Response: We recently re-evaluated this risk disclosure
and modified it to note that the effects of the 2007-2008 financial crisis may persist indefinitely. The Amendment included this
updated disclosure. We believe that the effects of the financial crisis continue to influence the financial markets and, at this
time, we believe the disclosure is appropriate.
4. Comment: “Derivatives risk” – page 13. If derivatives are a principal strategy, please relocate derivatives
disclosure to the summary prospectus.
Response: The portfolio managers do not intend
to use derivatives as a principal strategy.
If you have any questions regarding any of the
foregoing or require additional information, please call me at (617) 295-2565.
Sincerely yours,
/s/Caroline Pearson
Caroline Pearson
Managing Director
cc: Jeremy Senderowicz, Dechert LLP