Correspondence 0001493152-25-009959 from GraniteShares ETF Trust (CIK 0001689873)
GraniteShares ETF Trust (CIK 0001689873)
Date: March 12, 2025 · CIK: 0001689873 · Accession: 0001493152-25-009959
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 Mr. Bellacicco:
On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long IONQ Daily ETF, GraniteShares 2x Long SQ Daily ETF, GraniteShares 2x Long MARA Daily ETF, GraniteShares 2x Short MSTR Daily ETF, GraniteShares 2x Long MRVL Daily ETF, GraniteShares 2x Long PDD Daily ETF, GraniteShares 2x Long RDDT Daily ETF, GraniteShares 2x Long RIOT Daily ETF, GraniteShares 2x Long HOOD Daily ETF, GraniteShares 2x Long NOW Daily ETF, GraniteShares 2x Long SNOW Daily ETF, and GraniteShares 2x Long VRT Daily ETF (the “Funds”) filed a Post-Effective Amendment #75 to the Trust’s Registration Statement (the “Amendment”). The Amendment was filed pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended to revise the investment strategy and related disclosures.
On February 5, 2025, you provided comments to the Amendment to which we have responded. In a telephone conversation on March 5, 2025, you provided additional 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 23: For GraniteShares 2x RIOT Daily ETF, the Underlying Stock Risk still discloses that the performance of the Underlying Stock is subject to the risks of the consumer services industry. Please update to the correct industry.
Response: The Underlying Stock Risk disclosure has been amended through amendment with the following language: “Capital market services companies may be significantly affected by stock and bank trading activity, changes in governmental regulation, continuing increases in price competition, decreases in fees or fee related business, including investment banking, brokerage, asset management and other servicing fees, fluctuation in interest rates and other factors which could adversely affect financial markets.”
Comment 32: For GraniteShares 2x Long MARA Daily ETF, please consider disclosing risks related to delays in receipt of hardware due to customs inspections.
Response: The following risk disclosure has been amended through amendment: “Delays in Receipt of Hardware Due to Custom Inspections Risk: Custom inspections can lead to delivery delays, potentially causing issues like supply chain disruptions, missed delivery schedules, and unsatisfied customers, as well as potentially leading to additional fees and inventory shortages.”
March 12, 2025
Page
If you have any questions, please call the undersigned at (216) 566-5706.
Very
truly yours,
/s/
Andrew Davalla
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CORRESP
1
filename1.htm
March 12, 2025
Christopher
Bellacicco
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
Mr. Bellacicco:
On
December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long
IONQ Daily ETF, GraniteShares 2x Long SQ Daily ETF, GraniteShares 2x Long MARA Daily ETF, GraniteShares 2x Short MSTR Daily ETF, GraniteShares
2x Long MRVL Daily ETF, GraniteShares 2x Long PDD Daily ETF, GraniteShares 2x Long RDDT Daily ETF, GraniteShares 2x Long RIOT Daily ETF,
GraniteShares 2x Long HOOD Daily ETF, GraniteShares 2x Long NOW Daily ETF, GraniteShares 2x Long SNOW Daily ETF, and GraniteShares 2x
Long VRT Daily ETF (the “Funds”) filed a Post-Effective Amendment #75 to the Trust’s Registration Statement (the “Amendment”).
The Amendment was filed pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended to revise the investment strategy and
related disclosures.
On
February 5, 2025, you provided comments to the Amendment to which we have responded. In a telephone conversation on March 5, 2025, you
provided additional 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
23: For GraniteShares 2x RIOT Daily ETF, the Underlying Stock Risk still discloses that the performance of the Underlying Stock is
subject to the risks of the consumer services industry. Please update to the correct industry.
Response:
The Underlying Stock Risk disclosure has been amended through amendment with the following language: “Capital market services
companies may be significantly affected by stock and bank trading activity, changes in governmental regulation, continuing increases
in price competition, decreases in fees or fee related business, including investment banking, brokerage, asset management and other
servicing fees, fluctuation in interest rates and other factors which could adversely affect financial markets.”
Comment
32: For GraniteShares 2x Long MARA Daily ETF, please consider disclosing risks related to delays in receipt of hardware due to customs
inspections.
Response:
The following risk disclosure has been amended through amendment: “Delays in Receipt of Hardware Due to Custom Inspections Risk:
Custom inspections can lead to delivery delays, potentially causing issues like supply chain disruptions, missed delivery schedules,
and unsatisfied customers, as well as potentially leading to additional fees and inventory shortages.”
March
12, 2025
Page
2
If
you have any questions, please call the undersigned at (216) 566-5706.
Very
truly yours,
/s/
Andrew Davalla
Andrew
Davalla