Correspondence 0001104659-24-121481 from Calamos ETF Trust (CIK 0001579881)
Calamos ETF Trust (CIK 0001579881)
Date: Nov. 21, 2024 · CIK: 0001579881 · Accession: 0001104659-24-121481
AI Filing Summary & Sentiment
File numbers found in text: 333-191151, 811-22887
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CORRESP
1
filename1.htm
ROPES & GRAY LLP
191 North Wacker Drive, 32nd Floor
Chicago, IL 60606
WWW.ROPESGRAY.COM
November 21,2024 Rita Rubin
T +1 312-845-1241
Rita.Rubin@ropesgray.com
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Calamos ETF Trust (“Registrant” or “Trust”) on behalf of four of its series,
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 1
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 2
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 3
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 4
(each, a “Fund” and collectively, the “Funds”)
(File Nos. 333-191151 and 811-22887)
Ladies and Gentlemen:
On
behalf of the Registrant, in connection with amendments to four series of Calamos ETF Trust, we are filing today by electronic submission
via EDGAR pursuant to Rule 485(a)(1) a post-effective amendment (Post-Effective Amendment No. 48) to the Trust’s registration
statement on Form N-1A a copy of each of the following:
1. Prospectuses relating to the four ETFs (the “Prospectuses”); and
2. Statement of additional information relating to the four ETFs (the “SAI”).
Except
as indicated below, the disclosure for each of the ETFs is based on and substantially similar to disclosure previously reviewed by the
staff of the U.S. Securities and Exchange Commission (“SEC”) in the Registrant’s filing on Form N-1A (SEC Accession
Number 0001104659-24-102657) filed on September 25, 2024 pursuant to Rule 485(b) of the Securities Act of 1933, as amended, (the
“Securities Act”) (the “Precedent Filing”).
The
Registrant requests selective review of Post-Effective Amendment No. 48 in accordance with the SEC’s release on selective
review, Revised Procedures For Processing Registration Statements, Post-Effective Amendments and Preliminary Proxy Materials Filed
by Registered Investment Companies, Investment Company Act Release No. 13768 (February 15, 1984).
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Prospectuses
The
Precedent Filing registered the following ETFs which had the following characteristics:
Fund Name
Launch Date
Start of Outcome Period
Calamos Bitcoin Structured Alt Protection ETF — Month TBD 1
TBD
TBD
Calamos Bitcoin Structured Alt Protection ETF — Month TBD 2
TBD
TBD
Calamos Bitcoin Structured Alt Protection ETF — Month TBD 3
TBD
TBD
Calamos Bitcoin Structured Alt Protection ETF — Month TBD 4
TBD
TBD
The Registrant requests selective review of the Prospectuses listed
below. The Prospectuses are substantially similar to the prospectuses in the Precedent Filing. The primary differences are the ETF names,
launch dates, the investment objective and strategy with respect to the underlying ETP(s) and index, the types of options the Fund may
use to implement its strategy and the dates on which the respective outcome periods begin and reset for each of the four ETFs:1
Fund Name per Upcoming
Pre-Effective Registration
Statement Filing
Launch Date per
Upcoming Pre-Effective
Registration Statement
Filing
Outcome Period Reset dates per
Upcoming Pre-Effective
Registration Statement Filing
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 1
TBD
TBD
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 2
TBD
TBD
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 3
TBD
TBD
Calamos Bitcoin 100% Protection Strategy (1 yr) ETF — Month TBD 4
TBD
TBD
SAI
The
Registrant requests selective review of the SAI, which is being filed with language that is substantially similar to the Precedent
Filing. The differences in the disclosure in this SAI is that the new SAI will contain new ETF names, launch dates, the investment objective
and strategy with respect to the underlying ETP(s) and index, the types of options the Fund may use to implement its strategy and the
dates on which the outcome periods begin and reset.
1
As explained in more detail in the Prospectus of each series, the outcome period is an approximate one-year period over which each Fund
seeks to produce a targeted result. The Funds will not terminate after the conclusion of the Outcome Period. After the conclusion of the
Outcome Period, another will begin.
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Please direct any questions you may have with respect to this filing
to me at (312) 845-1241.
Very
truly yours,
/s/
Rita Rubin
Rita
Rubin, Esq.
cc:
John P. Calamos, Sr.
Erik D. Ojala, Esq.
J. Christopher Jackson, Esq.
Susan L. Schoenberger, Esq.
Paulita Pike, Esq.
Elizabeth Madsen, Esq.
C. Lawrence Zmerega, Esq.
Daniel Koningisor, Esq.