Correspondence 0001839882-23-034404 from Virtus ETF Trust II (CIK 0001648403)
Virtus ETF Trust II (CIK 0001648403)
Date: Dec. 21, 2023 · CIK: 0001648403 · Accession: 0001839882-23-034404
AI Filing Summary & Sentiment
File numbers found in text: 333-206600, 811-23078
Letter
Division of Investment Management, Disclosure Review and Accounting Office 100 F. Street, N.E. Washington, DC 20549 Re: Virtus ETF Trust II (the “Trust”) File Nos. 333-206600 and 811-23078
Dear Mr. Szilagyi:
I am writing in response to the comments you provided in our phone conversation on November 7, 2023, to the Trust’s Form N-CSR for the fiscal year ended July 31, 2023. For your convenience, I have reproduced your comments in italics below, followed by the responses of the Trust.
1. We remind you that the Trust and its management are responsible for the accuracy and adequacy of the disclosures notwithstanding any review, comment to action or absence of action by the staff.
RESPONSE: The Trust acknowledges the staff’s comment.
2. With respect to Item 4(d) of Form N-CSR, going forward, please include a sufficient description of the nature of the services comprising the fees disclosed under this category for the last two fiscal years.
RESPONSE: The Trust acknowledges the staff’s comment and will include the requested information on a go-forward basis.
Philadelphia, PA ● Malvern, PA ● Cherry Hill, NJ ● Newark, NJ ● Wilmington, DE ● Washington, DC ● New York, NY ● Chicago, IL
A Pennsylvania Limited Liability Partnership
* * *
Thank you for your comments. Please feel free to contact me at 215-564-8528 or, in my absence, Michael D. Mabry at 215-564-8011, if you have any additional questions or comments.
Very
truly yours,
/s/
Joel D. Corriero
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CORRESP
1
filename1.htm
Stradley
Ronon Stevens & Young, LLP
2005
Market Street
Suite
2600
Philadelphia,
PA 19103
Telephone
215.564.8000
Fax
215.564.8120
www.stradley.com
Joel
D Corriero
Partner
jcorriero@stradley.com
215.564.8528
December 21, 2023
Via EGAR Transmission
Mr. Brian Szilagyi, CPA
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review and Accounting Office
100 F. Street, N.E.
Washington, DC 20549
Re: Virtus ETF Trust II (the “Trust”)
File Nos. 333-206600 and 811-23078
Dear Mr. Szilagyi:
I am writing in response to
the comments you provided in our phone conversation on November 7, 2023, to the Trust’s Form N-CSR for the fiscal year ended July
31, 2023. For your convenience, I have reproduced your comments in italics below, followed by the responses of the Trust.
1. We remind you that the Trust and its management are responsible for the accuracy and adequacy of the
disclosures notwithstanding any review, comment to action or absence of action by the staff.
RESPONSE: The Trust acknowledges
the staff’s comment.
2. With respect to Item 4(d) of Form N-CSR, going forward, please include a sufficient description of
the nature of the services comprising the fees disclosed under this category for the last two fiscal years.
RESPONSE: The Trust acknowledges
the staff’s comment and will include the requested information on a go-forward basis.
Philadelphia, PA ● Malvern, PA ● Cherry
Hill, NJ ● Newark, NJ ● Wilmington, DE ● Washington, DC ● New York, NY ● Chicago, IL
A Pennsylvania Limited Liability Partnership
* * *
Thank you for your comments.
Please feel free to contact me at 215-564-8528 or, in my absence, Michael D. Mabry at 215-564-8011, if you have any additional questions
or comments.
Very
truly yours,
/s/
Joel D. Corriero
Joel
D. Corriero
cc: William Smalley
Daphne Chisolm
Michael Mabry