Correspondence 0001104659-23-005492 from Calamos ETF Trust (CIK 0001579881)
Calamos ETF Trust (CIK 0001579881)
Date: Jan. 20, 2023 · CIK: 0001579881 · Accession: 0001104659-23-005492
AI Filing Summary & Sentiment
File numbers found in text: 333-191151, 811-22887
Letter
VIA EDGAR CORRESPONDENCE United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 File Nos. 333-191151; 811-22887
Re: Calamos ETF Trust (the “Trust”)
Dear Ms. Larkin:
This letter responds to your additional comments received by telephone on January 18, 2023 regarding the registration statement filed on Form N-1A for Calamos ETF Trust (the “Trust”) with the Staff of the Securities and Exchange Commission (the “Staff”) on November 4, 2022 (the “Registration Statement”). The Registration Statement relates to the Calamos Antetokounmpo Global Sustainable Equities ETF (the “Fund”), a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.
Comment
The Staff notes that the seed financial statements indicate that the offering and organizational costs will be paid by CGAM, however p. 44 of the Registration Statement indicates under the heading “Expenses” that fees and expenses will be borne by the Subadviser. Please explain or update as appropriate.
Response to Comment 1
The Fund confirms the disclosure in the Registration Statement on p. 44 has been revised to state that the offering and organizational costs will be paid by the Adviser, CGAM, consistent with the seed financial statements.
Comment
The Fund’s expense structure appears to be arranged in a unitary fee structure whereby the Adviser is obligated to pay service providers on behalf of the Fund. Please supplementally describe if the Adviser is current with all payments to service providers. Additionally, please describe if the agreements to be filed with the Commission as exhibits to the Fund’s Registration Statement contain provisions whereby the Fund is contractually obligated to pay such service providers.
Response to Comment 2
The Adviser confirms that it is current with all payments to service providers. While certain service provider agreements may provide that the Fund is the obligated party to pay such service providers, the Adviser is contractually obligated to pay these expenses of the Fund pursuant to the Advisory Agreement with the Fund and this contractual obligation may not be terminated so long as the Advisory Agreement is in effect without the approval of shareholders.
* * * * * * * *
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
Chapman and Cutler
llp
Show Raw Text
CORRESP
1
filename1.htm
[Chapman
and Cutler LLP Letterhead]
January 20, 2023
VIA EDGAR CORRESPONDENCE
Lisa N. Larkin
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Calamos
ETF Trust (the “Trust”)
File
Nos. 333-191151; 811-22887
Dear Ms. Larkin:
This letter responds to your
additional comments received by telephone on January 18, 2023 regarding the registration statement filed on Form N-1A for Calamos
ETF Trust (the “Trust”) with the Staff of the Securities and Exchange Commission (the “Staff”) on
November 4, 2022 (the “Registration Statement”). The Registration Statement relates to the Calamos Antetokounmpo Global
Sustainable Equities ETF (the “Fund”), a series of the Trust. Capitalized terms used herein, but not otherwise defined,
have the meanings ascribed to them in the Registration Statement.
Comment
1
The Staff notes that the seed
financial statements indicate that the offering and organizational costs will be paid by CGAM, however p. 44 of the Registration Statement
indicates under the heading “Expenses” that fees and expenses will be borne by the Subadviser. Please explain or update
as appropriate.
Response
to Comment 1
The Fund confirms the disclosure
in the Registration Statement on p. 44 has been revised to state that the offering and organizational costs will be paid by the Adviser,
CGAM, consistent with the seed financial statements.
Comment
2
The Fund’s expense structure
appears to be arranged in a unitary fee structure whereby the Adviser is obligated to pay service providers on behalf of the Fund. Please
supplementally describe if the Adviser is current with all payments to service providers. Additionally, please describe if the agreements
to be filed with the Commission as exhibits to the Fund’s Registration Statement contain provisions whereby the Fund is contractually
obligated to pay such service providers.
Response
to Comment 2
The Adviser confirms that
it is current with all payments to service providers. While certain service provider agreements may provide that the Fund is the obligated
party to pay such service providers, the Adviser is contractually obligated to pay these expenses of the Fund pursuant to the Advisory
Agreement with the Fund and this contractual obligation may not be terminated so long as the Advisory Agreement is in effect without the
approval of shareholders.
* * * * * * * *
Please call me at (312) 845-3484
if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
Chapman and Cutler
llp
By:
/s/ Morrison C. Warren
Morrison C. Warren
2