Correspondence 0001999371-24-012809 from Virtus ETF Trust II (CIK 0001648403)
Virtus ETF Trust II (CIK 0001648403)
Date: Oct. 2, 2024 · CIK: 0001648403 · Accession: 0001999371-24-012809
AI Filing Summary & Sentiment
File numbers found in text: 333-206600, 811-23078
Letter
Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Virtus ETF Trust II (the “Registrant”) File Nos. 333-206600 and 811-23078
Dear Mr. Brodsky:
This correspondence responds to a follow-up comment received by the undersigned from the staff of the U.S. Securities and Exchange Commission (the “Staff”) during a telephone conversation on September 30, 2024, with respect to Post-Effective Amendment No. 87 and Amendment No. 89 to the Registrant’s Registration Statement on Form N-1A (the “Registration Statement”).
Set forth below are the Staff’s comment and the Registrant’s response thereto. Capitalized terms used and not defined herein have the meaning given to them in the Registration Statement.
Prospectus
Principal Investment Strategy
Comment 1: Follow-up to Response 5. The Staff disagrees with the Fund’s response and does not believe that the Fund’s definition of a medium market capitalization company complies with Rule 35d-1. Please revise as requested in the original comment.
Response: The disclosure has been revised consistent with this comment.
* * * * *
If you have any further comments or questions regarding this filing, please contact me at 860-503-1285 or by email at daphne.chisolm@virtus.com. Thank you for your attention to these matters.
Sincerely,
/s/ Daphne Chisolm
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CORRESP 1 filename1.htm 31 West 52nd Street, 17th Floor, New York, NY 10019 | 800.248.7971 | Virtus.com October 2, 2024 FILED VIA EDGAR Mr. Aaron Brodsky Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Virtus ETF Trust II (the “Registrant”) File Nos. 333-206600 and 811-23078 Dear Mr. Brodsky: This correspondence responds to a follow-up comment received by the undersigned from the staff of the U.S. Securities and Exchange Commission (the “Staff”) during a telephone conversation on September 30, 2024, with respect to Post-Effective Amendment No. 87 and Amendment No. 89 to the Registrant’s Registration Statement on Form N-1A (the “Registration Statement”). Set forth below are the Staff’s comment and the Registrant’s response thereto. Capitalized terms used and not defined herein have the meaning given to them in the Registration Statement. Prospectus Principal Investment Strategy Comment 1: Follow-up to Response 5. The Staff disagrees with the Fund’s response and does not believe that the Fund’s definition of a medium market capitalization company complies with Rule 35d-1. Please revise as requested in the original comment. Response: The disclosure has been revised consistent with this comment. * * * * * If you have any further comments or questions regarding this filing, please contact me at 860-503-1285 or by email at daphne.chisolm@virtus.com. Thank you for your attention to these matters. Sincerely, /s/ Daphne Chisolm Daphne Chisolm