Correspondence 0001193125-25-010204 from Cohen & Steers ETF Trust (CIK 0001590402)
Cohen & Steers ETF Trust (CIK 0001590402)
Date: Jan. 22, 2025 · CIK: 0001590402 · Accession: 0001193125-25-010204
AI Filing Summary & Sentiment
File numbers found in text: 333-281213, 811-22913
Letter
VIA EDGAR Division of Investment Management Washington, D.C. 20549 Re: Cohen & Steers ETF Trust (the “Trust”) Registration Statement on Form N-1A File Numbers: 333-281213; 811-22913
Dear Ms. Pumphrey,
This letter is being filed to respond to the comments received from you via telephone on December 18, 2024 regarding the Trust’s Pre-Effective Amendment No. 2 to its registration statement on Form N-1A (the “Registration Statement”) relating to Cohen & Steers Real Estate Active ETF, Cohen & Steers Preferred and Income Opportunities Active ETF, and Cohen & Steers Natural Resources Active ETF (each a “Fund” and together, the “Funds”), which was filed with the Securities and Exchange Commission (the “Commission”) on December 6, 2024. Your comments, together with the Trust’s responses thereto, are set forth below. The Trust’s responses will be reflected, to the extent applicable, in a Pre-Effective Amendment to the Trust’s Registration Statement to be filed at a later date. Capitalized terms not defined in this letter have the meanings assigned to them in the Registration Statement.
1. Staff Comment: Please include the name of the applicable Fund within each “Summary Section” heading on the “Table of Contents” page of the prospectus.
Response: The Trust will revise the “Table of Contents” page of the prospectus accordingly.
2. Staff Comment: The Staff notes that, in connection with the adoption of tailored shareholder reports, the discussion regarding the Board’s basis for approving the Investment Advisory Agreement will be included on each Fund’s Form N-CSR instead of its report to shareholders. Please update any references to the availability of such information accordingly.
Response: The Trust will revise its disclosure accordingly.
3. Staff Comment: Given that the disclosure pertaining to Cohen & Steers Real Estate Active ETF’s subadvisors that was previously included within the Trust’s Registration Statement has been removed, please confirm whether it is relevant to continue to include disclosure regarding the subadvisors’ proxy voting policies in Appendix A to the Registration Statement.
Response: The Trust respectfully notes that the Staff’s comment is no longer applicable given that the Trust will reinsert Cohen & Steers Real Estate Active ETF’s subadvisors in Pre-Effective Amendment No. 3 to the Registration Statement.
* * * * *
We hope the Staff finds these responses to adequately address the comments to the Registration Statement. Should members of the Staff have any questions or comments regarding these responses, they should call the undersigned at 212.796.9347.
Very truly yours,
/s/ Dana
DeVivo
Show Raw Text
CORRESP 1 filename1.htm CORRESP COHEN & STEERS ETF TRUST 1166 Avenue of the Americas, 30th Floor New York, New York 10036 January 22, 2025 VIA EDGAR Shandy Pumphrey Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Cohen & Steers ETF Trust (the “Trust”) Registration Statement on Form N-1A File Numbers: 333-281213; 811-22913 Dear Ms. Pumphrey, This letter is being filed to respond to the comments received from you via telephone on December 18, 2024 regarding the Trust’s Pre-Effective Amendment No. 2 to its registration statement on Form N-1A (the “Registration Statement”) relating to Cohen & Steers Real Estate Active ETF, Cohen & Steers Preferred and Income Opportunities Active ETF, and Cohen & Steers Natural Resources Active ETF (each a “Fund” and together, the “Funds”), which was filed with the Securities and Exchange Commission (the “Commission”) on December 6, 2024. Your comments, together with the Trust’s responses thereto, are set forth below. The Trust’s responses will be reflected, to the extent applicable, in a Pre-Effective Amendment to the Trust’s Registration Statement to be filed at a later date. Capitalized terms not defined in this letter have the meanings assigned to them in the Registration Statement. 1. Staff Comment: Please include the name of the applicable Fund within each “Summary Section” heading on the “Table of Contents” page of the prospectus. Response: The Trust will revise the “Table of Contents” page of the prospectus accordingly. 2. Staff Comment: The Staff notes that, in connection with the adoption of tailored shareholder reports, the discussion regarding the Board’s basis for approving the Investment Advisory Agreement will be included on each Fund’s Form N-CSR instead of its report to shareholders. Please update any references to the availability of such information accordingly. Response: The Trust will revise its disclosure accordingly. 3. Staff Comment: Given that the disclosure pertaining to Cohen & Steers Real Estate Active ETF’s subadvisors that was previously included within the Trust’s Registration Statement has been removed, please confirm whether it is relevant to continue to include disclosure regarding the subadvisors’ proxy voting policies in Appendix A to the Registration Statement. Response: The Trust respectfully notes that the Staff’s comment is no longer applicable given that the Trust will reinsert Cohen & Steers Real Estate Active ETF’s subadvisors in Pre-Effective Amendment No. 3 to the Registration Statement. * * * * * We hope the Staff finds these responses to adequately address the comments to the Registration Statement. Should members of the Staff have any questions or comments regarding these responses, they should call the undersigned at 212.796.9347. Very truly yours, /s/ Dana DeVivo Dana DeVivo Secretary and Chief Legal Officer cc: Brian McCabe, Ropes & Gray LLP Michael Doherty, Ropes & Gray LLP