Correspondence 0000894189-23-009177 from ETF Series Solutions (CIK 0001540305)
ETF Series Solutions (CIK 0001540305)
Date: Dec. 21, 2023 · CIK: 0001540305 · Accession: 0000894189-23-009177
AI Filing Summary & Sentiment
File numbers found in text: 333-179562, 811-22668
Letter
Division of Investment Management 100 F Street NE Washington, DC 20549 Re: ETF Series Solutions (the “Trust”) Range Cancer Therapeutics ETF (the “Fund”) (S000081227) File Nos. 333-179562 and 811-22668
Dear Ms. O’Neal:
For your convenience, the comments have been reproduced with a response following each comment.
Comment 1.Please disclose the number of components in the Range Cancer Therapeutics Index.
Response: The Trust has revised the disclosure to include the number of components in the Range Cancer Therapeutics Index.
Comment 2.With respect to the performance benchmark index, please show the new index as a secondary index until June 2024, at which time the old index can be removed and the new index can be shown as the primary index.
Response: The Trust notes that the S&P 500 is the Fund’s broad-based securities market index and that both the Loncar Cancer Immunotherapy Index and the Range Cancer Therapeutics Index are underlying indices. The Trust also notes that while the Average Annual Total Returns table reflects performance through December 31, 2022, the Range Cancer Therapeutics Index was not used by the Fund prior to June 20, 2023. Because the Fund did not track the Range Cancer Therapeutics Index during the period represented by the Average Annual Total Returns table, the Trust has not added this index. The Trust additionally notes that the Loncar Cancer Immunotherapy Index is no longer being calculated. The Trust has removed the Loncar Cancer Immunotherapy Index and has revised the disclosure as follows:
The table illustrates how the Fund’s average annual returns for the 1-year, 5-year, and since inception periods compare with those of the S&P 500 Index, a broad measure of market performance, and the Fund’s prior underlying index, the Loncar Cancer Immunotherapy Index.
* * *
If you have any questions or require further information, please contact me at amber.kopp@usbank.com.
Sincerely,
/s/ Amber C. Kopp
Show Raw Text
CORRESP 1 filename1.htm Document ETF Series Solutions 615 East Michigan Street | Milwaukee, Wisconsin 53202 December 21, 2023 Ms. Deborah L. O’Neal U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: ETF Series Solutions (the “Trust”) Range Cancer Therapeutics ETF (the “Fund”) (S000081227) File Nos. 333-179562 and 811-22668 Dear Ms. O’Neal: For your convenience, the comments have been reproduced with a response following each comment. Comment 1.Please disclose the number of components in the Range Cancer Therapeutics Index. Response: The Trust has revised the disclosure to include the number of components in the Range Cancer Therapeutics Index. Comment 2.With respect to the performance benchmark index, please show the new index as a secondary index until June 2024, at which time the old index can be removed and the new index can be shown as the primary index. Response: The Trust notes that the S&P 500 is the Fund’s broad-based securities market index and that both the Loncar Cancer Immunotherapy Index and the Range Cancer Therapeutics Index are underlying indices. The Trust also notes that while the Average Annual Total Returns table reflects performance through December 31, 2022, the Range Cancer Therapeutics Index was not used by the Fund prior to June 20, 2023. Because the Fund did not track the Range Cancer Therapeutics Index during the period represented by the Average Annual Total Returns table, the Trust has not added this index. The Trust additionally notes that the Loncar Cancer Immunotherapy Index is no longer being calculated. The Trust has removed the Loncar Cancer Immunotherapy Index and has revised the disclosure as follows: The table illustrates how the Fund’s average annual returns for the 1-year, 5-year, and since inception periods compare with those of the S&P 500 Index, a broad measure of market performance, and the Fund’s prior underlying index, the Loncar Cancer Immunotherapy Index. * * * If you have any questions or require further information, please contact me at amber.kopp@usbank.com. Sincerely, /s/ Amber C. Kopp Amber C. Kopp For U.S. Bank Global Fund Services, as administrator to the Trust 1