Correspondence 0001999371-24-013199 from Tidal Trust III (CIK 0001722388)
Tidal Trust III (CIK 0001722388)
Date: Oct. 10, 2024 · CIK: 0001722388 · Accession: 0001999371-24-013199
AI Filing Summary & Sentiment
File numbers found in text: 333-221764, 811-23312
Referenced dates: October 8, 2024
Letter
VIA EDGAR TRANSMISSION Division of Investment Management Washington, DC 20549 Re: Tidal Trust III (the “Trust”) Post-Effective Amendment No. 47 to the Trust’s Registration Statement on Form N-1A (the “Amendment”) File Nos. 811-23312; 333-221764
Dear Ms. Rossotto:
This correspondence provides an updated response to the comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or the “Commission”) on September 17, 2024, with respect to the Registration Statement and the Trust’s proposed new series, the Ned Davis Research 360o Dynamic Allocation ETF and Ned Davis Research 360o Core Equity ETF (each, a “Fund,” and together, the “Funds”).
In particular, the Trust’s response to comment 15, as presented in the response letter dated October 8, 2024, has been revised as follows:
15. The Staff notes that Fund discloses Growth and Value risk disclosures. Please include references to such factors in the principal investment strategies or delete, as appropriate.
Response: Regarding Value risk disclosures, the Trust respectfully notes that the principal investment strategy already states that "NDR’s 360° Approach aims to identify long-term capital appreciation opportunities through undervalued . . . stocks." As for Growth risk, the Trust responds by removing the risk factor from the Fund’s prospectus.
If you have any questions or require further information, please contact Michael Pellegrino at (262) 318-8442 or mpellegrino@tidalfg.com.
/s/ Michael Pellegrino
Michael Pellegrino
General Counsel
Tidal Investments LLC
Show Raw Text
CORRESP
1
filename1.htm
Tidal Trust III
234 West Florida Street, Suite 203
Milwaukee, Wisconsin 53204
October 10, 2024
VIA EDGAR TRANSMISSION
Karen Rossotto
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street NE
Washington, DC 20549
Re:
Tidal Trust III (the “Trust”)
Post-Effective Amendment No. 47 to the Trust’s Registration Statement on Form N-1A (the “Amendment”)
File Nos. 811-23312; 333-221764
Dear Ms. Rossotto:
This correspondence provides an updated response
to the comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or the “Commission”)
on September 17, 2024, with respect to the Registration Statement and the Trust’s proposed new series, the Ned Davis Research 360o
Dynamic Allocation ETF and Ned Davis Research 360o Core Equity ETF (each, a “Fund,” and together, the “Funds”).
In particular, the Trust’s response
to comment 15, as presented in the response letter dated October 8, 2024, has been revised as follows:
15. The Staff notes that Fund discloses Growth and Value risk disclosures.
Please include references to such factors in the principal investment strategies or delete, as appropriate.
Response: Regarding Value risk
disclosures, the Trust respectfully notes that the principal investment strategy already states that "NDR’s 360° Approach
aims to identify long-term capital appreciation opportunities through undervalued . . . stocks." As for Growth risk, the Trust responds
by removing the risk factor from the Fund’s prospectus.
If you have any questions or require further
information, please contact Michael Pellegrino at (262) 318-8442 or mpellegrino@tidalfg.com.
/s/ Michael Pellegrino
Michael Pellegrino
General Counsel
Tidal Investments LLC