Correspondence 0001493152-25-009946 from GraniteShares ETF Trust (CIK 0001689873)
GraniteShares ETF Trust (CIK 0001689873)
Date: March 12, 2025 · CIK: 0001689873 · Accession: 0001493152-25-009946
AI Filing Summary & Sentiment
File numbers found in text: 333-214796, 811-23214
Letter
Division of Investment Management U.S. Securities and Exchange Commission F Street, N.E. Washington, D.C. 20549
RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214
Dear Ms. McManus:
On March 6, 2025, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long AAL Daily ETF, GraniteShares 1x Short AAL Daily ETF, GraniteShares 2x Short AAL Daily ETF, GraniteShares 1x Short AAPL Daily ETF, GraniteShares 2x Short AAPL Daily ETF, GraniteShares 1x Short AMD Daily ETF, GraniteShares 2x Short AMD Daily ETF, GraniteShares 2x Short COIN Daily ETF, GraniteShares 2x Long JPM Daily ETF, GraniteShares 1x Short JPM Daily ETF, GraniteShares 2x Short JPM Daily ETF, GraniteShares 2x Long LCID Daily ETF, GraniteShares 1x Short LCID Daily ETF, GraniteShares 2x Short LCID Daily ETF, GraniteShares 1x Short META Daily ETF, GraniteShares 2x Short META Daily ETF, GraniteShares 1x Short NVDA Daily ETF, GraniteShares 2x Short NVDA Daily ETF, GraniteShares 2x Long RIVN Daily ETF, GraniteShares 1x Short RIVN Daily ETF, GraniteShares 2x Short RIVN Daily ETF, GraniteShares 2x Long TSLA Daily ETF, GraniteShares 1x Short TSLA Daily ETF, GraniteShares 2x Short TSLA Daily ETF, GraniteShares 2x Long XOM Daily ETF, GraniteShares 1x Short XOM Daily ETF and GraniteShares 2x Short XOM Daily ETF (the “Funds”) filed a Post-Effective Amendment #82 to the Trust’s Registration Statement (the “Amendment”). The Amendment was filed pursuant to Rule 485(b) under the Securities Act of 1933, as amended to delay effectiveness of Post-Effective Amendment #72.
In a telephone conversation on March 7, 2025, you provided comments to the Amendment. Below, please find those comments and the Registrant’s responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language to a Fund’s prospectus is in italics and deleted language appears struck through.
Comment 1: Pursuant to Rule 485(b), a BXT filing delays effectiveness thirty days or less. If in thirty days, the Trust wishes to delay effectiveness further, another BXT would need to be filed for each filing, respectively. Please respond to this comment in EDGAR to reflect the Trust’s understanding of the Comment.
Response: The registrant understands the comments and has revised the delay of effectiveness to 30 days.
If you have any questions, please call the undersigned at (216) 566-5706.
March 12, 2025
Page
Very
truly yours,
/s/
Andrew Davalla
Show Raw Text
CORRESP
1
filename1.htm
March
12, 2025
Kim
McManus
Division
of Investment Management
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
RE:
GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214
Dear
Ms. McManus:
On
March 6, 2025, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long AAL
Daily ETF, GraniteShares 1x Short AAL Daily ETF, GraniteShares 2x Short AAL Daily ETF, GraniteShares 1x Short AAPL Daily ETF, GraniteShares
2x Short AAPL Daily ETF, GraniteShares 1x Short AMD Daily ETF, GraniteShares 2x Short AMD Daily ETF, GraniteShares 2x Short COIN Daily
ETF, GraniteShares 2x Long JPM Daily ETF, GraniteShares 1x Short JPM Daily ETF, GraniteShares 2x Short JPM Daily ETF, GraniteShares 2x
Long LCID Daily ETF, GraniteShares 1x Short LCID Daily ETF, GraniteShares 2x Short LCID Daily ETF, GraniteShares 1x Short META Daily
ETF, GraniteShares 2x Short META Daily ETF, GraniteShares 1x Short NVDA Daily ETF, GraniteShares 2x Short NVDA Daily ETF, GraniteShares
2x Long RIVN Daily ETF, GraniteShares 1x Short RIVN Daily ETF, GraniteShares 2x Short RIVN Daily ETF, GraniteShares 2x Long TSLA Daily
ETF, GraniteShares 1x Short TSLA Daily ETF, GraniteShares 2x Short TSLA Daily ETF, GraniteShares 2x Long XOM Daily ETF, GraniteShares
1x Short XOM Daily ETF and GraniteShares 2x Short XOM Daily ETF (the “Funds”) filed a Post-Effective Amendment #82 to the
Trust’s Registration Statement (the “Amendment”). The Amendment was filed pursuant to Rule 485(b) under the Securities
Act of 1933, as amended to delay effectiveness of Post-Effective Amendment #72.
In
a telephone conversation on March 7, 2025, you provided comments to the Amendment. Below, please find those comments and the Registrant’s
responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language to a Fund’s
prospectus is in italics and deleted language appears struck through.
Comment
1: Pursuant to Rule 485(b), a BXT filing delays effectiveness thirty days or less. If in thirty days, the Trust wishes to delay effectiveness
further, another BXT would need to be filed for each filing, respectively. Please respond to this comment in EDGAR to reflect the Trust’s
understanding of the Comment.
Response:
The registrant understands the comments and has revised the delay of effectiveness to 30 days.
If
you have any questions, please call the undersigned at (216) 566-5706.
March
12, 2025
Page
2
Very
truly yours,
/s/
Andrew Davalla
Andrew
Davalla