Correspondence 0001999371-25-013160 from Virtus ETF Trust II (CIK 0001648403)
Virtus ETF Trust II (CIK 0001648403)
Date: Sept. 12, 2025 · CIK: 0001648403 · Accession: 0001999371-25-013160
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-206600, 811-23078
Letter
September 12, 2025 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:
We are in receipt of your follow-up comment regarding the registration statement on Form N-1A (the "Registration Statement") for the Registrant with respect to Virtus IG Public & Private Credit ETF (the "Fund").
Below is your follow-up comment and the Registrant's corresponding response. Capitalized terms used and not defined herein have the meaning given to them in the Registration Statement.
Comment : The Registrant previously stated the following:
"The Fund intends on obtaining private credit exposure primarily through investments in CLOs. The Fund reserves the ability to obtain such exposure through investments in closed-end funds and business development companies, although it is not currently contemplated."
Should the Fund choose to invest in closed-end funds or business development companies in the future, please update the disclosure to include these instruments as potential investment options.
Response : The Registrant confirms that, should the Fund determine in the future to pursue exposure to private credit through investments in closed-end funds or business development companies, it will update the Registration Statement's disclosure accordingly to ensure that investors are appropriately informed of these potential investment options.
Sincerely,
/s/ Daphne Chisolm
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CORRESP 1 filename1.htm September 12, 2025 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: We are in receipt of your follow-up comment regarding the registration statement on Form N-1A (the "Registration Statement") for the Registrant with respect to Virtus IG Public & Private Credit ETF (the "Fund"). Below is your follow-up comment and the Registrant's corresponding response. Capitalized terms used and not defined herein have the meaning given to them in the Registration Statement. Comment : The Registrant previously stated the following: "The Fund intends on obtaining private credit exposure primarily through investments in CLOs. The Fund reserves the ability to obtain such exposure through investments in closed-end funds and business development companies, although it is not currently contemplated." Should the Fund choose to invest in closed-end funds or business development companies in the future, please update the disclosure to include these instruments as potential investment options. Response : The Registrant confirms that, should the Fund determine in the future to pursue exposure to private credit through investments in closed-end funds or business development companies, it will update the Registration Statement's disclosure accordingly to ensure that investors are appropriately informed of these potential investment options. Sincerely, /s/ Daphne Chisolm Daphne Chisolm