Correspondence 0001387131-23-008445 from Tidal ETF Trust (CIK 0001742912)
Tidal ETF Trust (CIK 0001742912)
Date: July 14, 2023 · CIK: 0001742912 · Accession: 0001387131-23-008445
AI Filing Summary & Sentiment
File numbers found in text: 333-227298, 811-23377
Letter
VIA EDGAR TRANSMISSION Division of Investment Management, Disclosure Review Office Washington, D.C. 20549 Re: Tidal ETF Trust (the “Trust”) Post-Effective Amendment No. 179 to the Trust’s Registration Statement on Form N-1A (the “Amendment”) File Nos. 333-227298, 811-23377
Dear Ms. Rossotto:
This correspondence responds to comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or the “Commission”) on July 13, 2023, with respect to the Amendment, which was filed to reflect a material change of the name of the Sound Equity Income ETF, a series of the Trust, to the Sound Equity Dividend Income ETF, and to reflect a corresponding revision to the Fund’s 80% investment policy. The Amendment also includes the following series of the Trust: Sound Enhanced Fixed Income ETF, Sound Enhanced Equity Income ETF, Sound Fixed Income ETF, and Sound Total Return ETF (together, with the Sound Equity Dividend Income ETF, the “Funds”). For your convenience, the comments have been reproduced with responses following each comment. Capitalized terms not otherwise defined have the same meaning as in the Amendment.
Prospectus
1. Please order the risks to prioritize the risks that are most likely to adversely affect each Fund’s net assets, yield, and total return. Please note that after listing the most significant risks to each Fund, other principal risks may be alphabetized. See ADI 2019-08 Improving Principal Risk Disclosure. Accordingly, delete references stating that the principal risks are stated in alphabetical order.
Response: The Trust confirms that the Principal Investment Risk sections for the Funds have been reordered accordingly.
2. Update Recent Market Event Risks as may be needed.
Response: The Trust confirms that the Recent Market Event Risks for the Funds have been updated.
If you have any questions or require further information, please contact Michael Pellegrino at (844) 986-7700 #746 or mpellegrino@tidalfg.com.
Sincerely,
/s/ Michael
T. Pellegrino
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CORRESP
1
filename1.htm
Tidal
ETF Trust
234
West Florida Street, Suite 203
Milwaukee,
Wisconsin 53204
July
14, 2023
VIA
EDGAR TRANSMISSION
Ms.
Karen Rossotto
Division
of Investment Management, Disclosure Review Office
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
Re:
Tidal
ETF Trust (the “Trust”)
Post-Effective
Amendment No. 179 to the Trust’s Registration Statement on Form N-1A (the “Amendment”)
File
Nos. 333-227298, 811-23377
Dear
Ms. Rossotto:
This
correspondence responds to comments the Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff”
or the “Commission”) on July 13, 2023, with respect to the Amendment, which was filed to reflect a material change of the
name of the Sound Equity Income ETF, a series of the Trust, to the Sound Equity Dividend Income ETF, and to reflect a corresponding revision
to the Fund’s 80% investment policy. The Amendment also includes the following series of the Trust: Sound Enhanced Fixed Income
ETF, Sound Enhanced Equity Income ETF, Sound Fixed Income ETF, and Sound Total Return ETF (together, with the Sound Equity Dividend Income
ETF, the “Funds”). For your convenience, the comments have been reproduced with responses following each comment. Capitalized
terms not otherwise defined have the same meaning as in the Amendment.
Prospectus
1. Please
order the risks to prioritize the risks that are most likely to adversely affect each Fund’s
net assets, yield, and total return. Please note that after listing the most significant
risks to each Fund, other principal risks may be alphabetized. See ADI 2019-08 Improving
Principal Risk Disclosure. Accordingly, delete references stating that the principal risks
are stated in alphabetical order.
Response:
The Trust confirms that the Principal Investment Risk sections for the Funds have been reordered accordingly.
2. Update
Recent Market Event Risks as may be needed.
Response:
The Trust confirms that the Recent Market Event Risks for the Funds have been updated.
If
you have any questions or require further information, please contact Michael Pellegrino at (844) 986-7700 #746 or mpellegrino@tidalfg.com.
Sincerely,
/s/ Michael
T. Pellegrino
Michael
T. Pellegrino, General Counsel
Toroso Investments, LLC