SEC Company Response from DBX ETF TRUST (CIK 0001503123) — Jan 20, 2026
DBX ETF TRUST (CIK 0001503123)
Date: Jan. 20, 2026 · CIK: 0001503123 · Accession: 0000088053-26-000012
AI Filing Summary & Sentiment
Reasoning
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: Kalkidan Ezra Re: Post-Effective Amendment No. 522 to the Registration Statement on Form N-1A of Xtrackers Europe Defense Technologies ETF (the “Fund”), a series of DBX ETF Trust (the “Trust”) (Reg. Nos. 333-170122; 811-22487)
Dear Ms. Ezra,
This letter is submitted on behalf of the Fund in response to comments of the Staff of the Securities and Exchange Commission (“SEC”) regarding the above-referenced Post-Effective Amendment (the “Amendment”), which comments were received via telephone on December 30, 2025. The Amendment was filed on behalf of the Fund on November 5, 2025, with an effective date of January 20, 2026. Subsequently, the Registrant filed Post-Effective Amendment No. 525 on January 15, 2026, establishing a new effective date of January 27, 2026.
The Staff’s comments are restated below, followed by the Fund’s responses. For the Staff’s reference, a marked copy of the Fund’s Prospectus is included as Attachment A to this letter. The marked copy of the Prospectus shows changes from the Amendment, including changes made in response to the Staff’s comments.
1. Comment: Please file the Fund’s response on EDGAR as a correspondence at least five business days before the effective date.
Response: This response is being filed at least five business days before the effective date as requested.
2. Comment: Please reflect any disclosure changes in the correspondence filing or, alternatively, please send redlines via email that show all disclosure changes between the Fund’s 485(a) filing and 485(b) filing.
Response: A redlined copy of the Fund’s prospectus showing all disclosure changes between the Fund’s 485(a) and 485(b) filing was provided to the Staff by email on January 20, 2026.
3. Comment: Comments on disclosure in one section of the registration statement apply to similar disclosures throughout the registration statement and should be updated accordingly.
Response: The Registrant acknowledges this comment and has made changes throughout the registration statement as applicable.
4. Comment: Please provide a completed fee table and example prior to effectiveness.
Response: The Fund’s completed fee table and example were provided to the Staff by email on January 20, 2026.
5. Comment: Regarding “Principal Investment Strategies”, please explain, supplementally, whether “50-25” in the index name is a reference to the number of holdings in the index. If so, note that the number of fund holdings, in normal circumstances, should be consistent with the index name.
Response: The term “50-25” in the name of the Underlying Index does not refer to the number of securities included in the index. It is a reference to the selection criteria used in constructing the index.
6. Comment: Under “Principal Investment Strategies,” it is stated that the “Underlying Index and the Parent Index are calculated and maintained by STOXX Ltd.”. Please clarify supplementally that the index is rules-based.
Response: Note that the Underlying Index is a rules-based index.
7. Comment: Under the “Underlying Index – Eligible Universe and Constituent Selection” section, what does the Fund mean by “aggregated revenue exposure”? Is it a numerical threshold or percentage threshold? Please explain the cut-off used by the index and provide 2 edge case examples of a company that would, and a company that would not, meet the criteria. Additionally, please provide more information about the process that the Index Provider uses to evaluate patent citations. To the extent that certain key technologies are not patented, please consider the need for risk disclosure addressing gaps in industry coverage based on the index construction.
Response: The Underlying Index screens for companies that have at least 25% of revenue exposure in the cybersecurity, space and defense sectors. The aggregated revenue exposure is the total percentage of revenues generated from these three sectors. An example of a company that would meet the criteria is Rheinmetall AG while a company that would not meet the criteria would be secunet Security Networks AG.
The Index Provider evaluates patent citations using data provided by EconSight, a Switzerland-based business consultant with extensive experience evaluating companies’ use of technology. Using data, the Index Provider assesses a company’s patent exposure by looking at patent quality (a product of the number of patent citations and the countries covered by the patent) as well as patent specialization (the number of active patents a company holds associated with the technologies covered by the index divided by the total number of active patents the company holds). Using these two metrics – patent quality and patent specialization – the Index Provider identifies companies it believes demonstrate technological innovation in the defense, cybersecurity and space sectors. We have modified the prospectus to add disclosure that companies can be excluded from the Underlying Index if they do not hold patents on technologies they provide.
8. Comment: Under the “Underlying Index – Eligible Universe and Constituent Selection” section, regarding the statement “Constituent companies must also comply with certain industry classification
and liquidity criteria”, please, supplementally, explain what “certain industry classifications” are by providing an example.
Response: The Underlying Index identifies specific Industry Classification Benchmark (“ICB”) industry classifications that are excluded from the Underlying Index. Those classifications are listed in the prospectus as the health care, financials, real estate, consumer discretionary and consumer staples sectors.
9. Comment: Under “The Fund’s Investment Strategy,” the disclosure notes that “securities selected are expected to have, in the aggregate, investment characteristics (based on factors such as market capitalization and industry weightings), fundamental characteristics (such as return variability and yield), and liquidity measures similar to those of the Underlying Index.” Supplementally, explain what occurs when securities selected do not have, in the aggregate, investment characteristics (based on factors such as market capitalization and industry weightings), fundamental characteristics (such as return variability and yield), and liquidity measures similar to those of the Underlying Index.
Response: The Fund expects to track the Underlying Index using a full replication indexing strategy when possible. However, as stated in the Fund’s prospectus, if it is not possible at times for the Fund to use a full replication indexing strategy to replicate the Underlying Index, the Fund will instead hold a representative sampling indexing strategy to track the Underlying Index. Using a representative sampling indexing strategy, portfolio management chooses to purchase securities that have, in the aggregate, features that are similar to the securities included in the Underlying Index. Portfolio management monitors holdings and makes adjustments as necessary to maintain a representative sampling of the Underlying Index.
10. Comment: Please disclose the countries, market cap ranges, and sectors that the Underlying Index will have significant exposure to. If that level of specificity is not possible, you may specify the continent(s) rather than the countries.
Response: Disclosure regarding the countries and sectors that the Underlying Index currently has significant exposure to has been added to the prospectus, together with market cap ranges.
11. Comment: Under the “MAIN RISKS” section, please consider including Index Provider risk.
Response: We have reviewed our risk disclosure and have determined that an existing risk, “Index-related risk,” provides disclosure that might otherwise appear under an “Index Provider risk” heading.
12. Comment: In the “MAIN RISKS” section, “Stock market risk” notes “To the extent that the fund invests in a particular geographic region, capitalization or sector, the fund’s performance may be affected by the general performance of that region, capitalization or sector.” Since the Fund’s name contains the word “Europe”, which is a geographic region, please tailor a sentence in “Stock market risk” to reflect the geographic focus discussed in the investment strategies discussion and in the Fund’s name.
Response: While “Stock market risk” refers in general terms to the risks inherent in focusing investment in one country or region, the prospectus also includes “Geographic focus risk” and “European investment risk.” We respectfully decline to add specific European risk disclosure to “Stock market risk,” but we have changed the order of risks to make European investment risk more prominent.
13. Comment: The Fund included risks related to investing in France, the United Kingdom, and Germany in Item 9 but not Item 4. Please consider adding this risk disclosure to Item 4.
Response: It is our practice to add risk disclosure regarding investments in specific countries to Item 4 when 25% or more of the Underlying Index is represented by a country. For country exposure that is significant but not at the 25% level we include country specific risk in Item 9 only. Based on information we have on the current Underlying Index composition, we have included risk of investing in France in Item 9 only. However, since the United Kingdom currently represents more than 25% of the Underlying Index, we have included risk of investing in the United Kingdom in both Item 4 and Item 9.
14. Comment: Please consider including a sector risk and including “Defense and aerospace companies risk” and “Cybersecurity companies risk” as bullet points.
Response: Note that our practice with respect to sector risks is to include a risk called “Focus risk” to describe the general risks of investing in one or a few sectors, followed by individual risks factors for the relevant industries or sectors. The prospectus includes “Focus risk,” “Defense and Aerospace companies risk” and “Cybersecurity companies risk.” We respectfully decline to move the industry-specific risks to be part of “Focus risk” or a “Sector risk.”
If you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-3681 (office phone) or, alternatively, please email me at laura.mccollum@dws.com.
Sincerely yours,
/s/Laura McCollum
Show Raw Text
CORRESP
1
filename1.htm
EDGAR HTML
DWS Investment Management Americas, Inc.
100 Summer Street
Boston, MA 02110
January 20, 2026
VIA EDGAR
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attn: Kalkidan Ezra
Re:
Post-Effective Amendment No. 522 to the Registration Statement on Form N-1A of Xtrackers Europe Defense Technologies ETF (the “Fund”), a series of DBX ETF Trust (the “Trust”) (Reg. Nos. 333-170122; 811-22487)
Dear Ms. Ezra,
This letter is submitted on behalf of the Fund in
response to comments of the Staff of the Securities and Exchange Commission (“SEC”) regarding the above-referenced Post-Effective
Amendment (the “Amendment”), which comments were received via telephone on December 30, 2025. The Amendment was filed on behalf
of the Fund on November 5, 2025, with an effective date of January 20, 2026. Subsequently, the Registrant filed Post-Effective Amendment
No. 525 on January 15, 2026, establishing a new effective date of January 27, 2026.
The Staff’s comments are restated below, followed
by the Fund’s responses. For the Staff’s reference, a marked copy of the Fund’s Prospectus is included as Attachment
A to this letter. The marked copy of the Prospectus shows changes from the Amendment, including changes made in response to the Staff’s
comments.
1. Comment: Please file the Fund’s response on EDGAR as a correspondence at least five business
days before the effective date.
Response: This response is being
filed at least five business days before the effective date as requested.
2. Comment: Please reflect any disclosure changes in the correspondence filing or, alternatively,
please send redlines via email that show all disclosure changes between the Fund’s 485(a) filing and 485(b) filing.
Response: A redlined copy of the
Fund’s prospectus showing all disclosure changes between the Fund’s 485(a) and 485(b) filing was provided to the Staff by
email on January 20, 2026.
3. Comment: Comments on disclosure in one section of the registration statement apply to similar disclosures
throughout the registration statement and should be updated accordingly.
Response: The Registrant acknowledges
this comment and has made changes throughout the registration statement as applicable.
4. Comment: Please provide a completed fee table and example prior to effectiveness.
Response: The Fund’s completed
fee table and example were provided to the Staff by email on January 20, 2026.
5. Comment: Regarding “Principal Investment Strategies”, please explain, supplementally,
whether “50-25” in the index name is a reference to the number of holdings in the index. If so, note that the number of fund
holdings, in normal circumstances, should be consistent with the index name.
Response: The term “50-25”
in the name of the Underlying Index does not refer to the number of securities included in the index. It is a reference to the selection
criteria used in constructing the index.
6. Comment: Under “Principal Investment Strategies,” it is stated that the “Underlying
Index and the Parent Index are calculated and maintained by STOXX Ltd.”. Please clarify supplementally that the index is rules-based.
Response: Note that the Underlying
Index is a rules-based index.
7. Comment: Under the “Underlying Index – Eligible Universe
and Constituent Selection” section, what does the Fund mean by “aggregated revenue exposure”? Is it a numerical threshold
or percentage threshold? Please explain the cut-off used by the index and provide 2 edge case examples of a company that would, and a
company that would not, meet the criteria. Additionally, please provide more information about the process that the Index Provider uses
to evaluate patent citations. To the extent that certain key technologies are not patented, please consider the need for risk disclosure
addressing gaps in industry coverage based on the index construction.
Response: The Underlying Index screens
for companies that have at least 25% of revenue exposure in the cybersecurity, space and defense sectors. The aggregated revenue exposure
is the total percentage of revenues generated from these three sectors. An example of a company that would meet the criteria is Rheinmetall
AG while a company that would not meet the criteria would be secunet Security Networks AG.
The Index Provider evaluates patent citations
using data provided by EconSight, a Switzerland-based business consultant with extensive experience evaluating companies’ use of
technology. Using data, the Index Provider assesses a company’s patent exposure by looking at patent quality (a product of
the number of patent citations and the countries covered by the patent) as well as patent specialization (the number of active
patents a company holds associated with the technologies covered by the index divided by the total number of active patents the company
holds). Using these two metrics – patent quality and patent specialization – the Index Provider identifies companies it believes
demonstrate technological innovation in the defense, cybersecurity and space sectors. We have modified the prospectus to add disclosure
that companies can be excluded from the Underlying Index if they do not hold patents on technologies they provide.
8. Comment: Under the “Underlying Index – Eligible Universe and Constituent Selection”
section, regarding the statement “Constituent companies must also comply with certain industry classification
2
and
liquidity criteria”, please, supplementally, explain what “certain industry classifications” are by providing an example.
Response: The Underlying Index identifies
specific Industry Classification Benchmark (“ICB”) industry classifications that are excluded from the Underlying Index. Those
classifications are listed in the prospectus as the health care, financials, real estate, consumer discretionary and consumer staples
sectors.
9. Comment: Under “The Fund’s Investment Strategy,” the disclosure notes that “securities
selected are expected to have, in the aggregate, investment characteristics (based on factors such as market
capitalization and industry weightings), fundamental characteristics (such as return variability and yield), and liquidity measures similar
to those of the Underlying Index.” Supplementally, explain what occurs when securities selected do not have, in the aggregate, investment
characteristics (based on factors such as market capitalization and industry weightings), fundamental characteristics (such as return
variability and yield), and liquidity measures similar to those of the Underlying Index.
Response: The Fund expects to track
the Underlying Index using a full replication indexing strategy when possible. However, as stated in the Fund’s prospectus, if it
is not possible at times for the Fund to use a full replication indexing strategy to replicate the Underlying Index, the Fund will instead
hold a representative sampling indexing strategy to track the Underlying Index. Using a representative sampling indexing strategy, portfolio
management chooses to purchase securities that have, in the aggregate, features that are similar to the securities included in the Underlying
Index. Portfolio management monitors holdings and makes adjustments as necessary to maintain a representative sampling of the Underlying
Index.
10. Comment: Please disclose the countries, market cap ranges, and sectors that the Underlying Index
will have significant exposure to. If that level of specificity is not possible, you may specify the continent(s) rather than the countries.
Response: Disclosure regarding the
countries and sectors that the Underlying Index currently has significant exposure to has been added to the prospectus, together with
market cap ranges.
11. Comment: Under the “MAIN RISKS” section, please consider including Index Provider risk.
Response: We have reviewed our risk
disclosure and have determined that an existing risk, “Index-related risk,” provides disclosure that might otherwise appear
under an “Index Provider risk” heading.
12. Comment: In the “MAIN RISKS” section, “Stock market risk” notes “To
the extent that the fund invests in a particular geographic region, capitalization or sector, the fund’s performance may be affected
by the general performance of that region, capitalization or sector.” Since the Fund’s name contains the word “Europe”,
which is a geographic region, please tailor a sentence in “Stock market risk” to reflect the geographic focus discussed in
the investment strategies discussion and in the Fund’s name.
Response: While “Stock market
risk” refers in general terms to the risks inherent in focusing investment in one country or region, the prospectus also includes
“Geographic focus risk” and “European investment risk.” We respectfully decline to add specific European risk
disclosure to “Stock market risk,” but we have changed the order of risks to make European investment risk more prominent.
3
13. Comment: The Fund included risks related to investing in France, the United Kingdom, and Germany
in Item 9 but not Item 4. Please consider adding this risk disclosure to Item 4.
Response: It is our practice to
add risk disclosure regarding investments in specific countries to Item 4 when 25% or more of the Underlying Index is represented by a
country. For country exposure that is significant but not at the 25% level we include country specific risk in Item 9 only. Based on information
we have on the current Underlying Index composition, we have included risk of investing in France in Item 9 only. However, since the United
Kingdom currently represents more than 25% of the Underlying Index, we have included risk of investing in the United Kingdom in both Item
4 and Item 9.
14. Comment: Please consider including a sector risk and including “Defense and aerospace companies
risk” and “Cybersecurity companies risk” as bullet points.
Response: Note that our practice
with respect to sector risks is to include a risk called “Focus risk” to describe the general risks of investing in one or
a few sectors, followed by individual risks factors for the relevant industries or sectors. The prospectus includes “Focus risk,”
“Defense and Aerospace companies risk” and “Cybersecurity companies risk.” We respectfully decline to move the
industry-specific risks to be part of “Focus risk” or a “Sector risk.”
If
you have any questions regarding any of the foregoing or require additional information, please call me at (617) 295-3681 (office phone)
or, alternatively, please email me at laura.mccollum@dws.com.
Sincerely yours,
/s/Laura McCollum
Laura McCollum
Senior Legal Counsel
DWS Investment
Management Americas, Inc.
cc: John Marten, Vedder Price P.C.
4
ATTACHMENT A
Prospectus
January 27, 2026
Xtrackers Europe Defense Technologies ETF
NASDAQ: XDEF
The Securities and Exchange Commission (“SEC”) has not approved or disapproved these securities or passed upon the adequacy of this Prospectus. Any representation to the contrary is a criminal
offense.
Table of Contents
Xtrackers Europe Defense
Technologies ETF
Investment Objective
1
Fees and Expenses
1
Principal Investment Strategies
1
Main Risks
3
Past Performance
9
Management
9
Purchase and Sale of Fund Shares
9
Tax Information
9
Payments to Broker-Dealers and
Other Financial Intermediaries
9
Fund Details
Additional Information About Fund Strategies,
Underlying Index Information and Risks
10
Other Policies and Risks
19
Who Manages and Oversees the Fund
19
Management
20
Investing in the Fund
Buying and Selling Shares
22
Creations and Redemptions
23
Dividends and Distributions
24
Taxes
25
Distribution
26
Premium/Discount Information
27
Financial Highlights
28
Appendix
29
Index Provider and License
29
Disclaimers
29
Your investment in the fund is not a bank deposit and is not insured or guaranteed
by the Federal Deposit Insurance Corporation or any other government agency, entity or person.
Xtrackers Europe Defense Technologies ETF
Ticker: XDEF
Stock Exchange: NASDAQ
Investment Objective
The fund seeks investment results that correspond generally to the performance, before fees and expenses, of the STOXX Europe Total Market Defence, Space and Cybersecurity Innovation 50-25 Index.
Fees and Expenses
These are the fees and expenses that you will pay when you buy, hold and sell shares. You may also pay other fees, such as brokerage commissions and other fees to financial intermediaries on the purchase and sale of shares of the fund, which are not reflected in the table and example below.
ANNUAL FUND OPERATING EXPENSES
(expenses that you pay each year as a % of the value of your investment)
Management fee
0.35
Other Expenses1
None
Total annual fund operating expenses
0.35
1Because the fund is new, “Other Expenses” are based on estimated amounts for the current fiscal year.
EXAMPLE
This Example is intended to help you compare the cost of investing in the fund with the cost of investing in other funds. The Example assumes that you invest $10,000 in the fund for the time periods indicated and then sell all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the fund's operating expenses remain the same. The Example does not take into