Correspondence 0001999371-24-012293 from Tidal ETF Trust (CIK 0001742912)
Tidal ETF Trust (CIK 0001742912)
Date: Sept. 24, 2024 · CIK: 0001742912 · Accession: 0001999371-24-012293
AI Filing Summary & Sentiment
File numbers found in text: 333-281819
Letter
VIA EDGAR TRANSMISSION Division of Investment Management Washington, D.C. 20549 Re: Tidal ETF Trust (the “Trust”) Form N-14 File No. 333-281819
Dear Mr. Burak:
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 September 23, 2024, with respect to the Form N-14 Proxy Statement and Prospectus (the “N-14”) regarding the proposed reorganization of the Unusual Whales Subversive Democratic Trading ETF and the Unusual Whales Subversive Republican Trading ETF (“Target Funds”), each a series of Series Portfolios Trust (the “SPT”), into the Unusual Whales Subversive Democratic Trading ETF and the Unusual Whales Subversive Republican Trading ETF, respectively (“Acquiring Funds”), each a newly created series of the Trust.
Capitalized terms not otherwise defined have the same meaning as in the filing.
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 filing.
1. On page 5 and page 30 of the proxy statement/prospectus, it states that each Acquiring Fund is the accounting survivor of its proposed reorganization. Please explain supplementally how this is correct if the Acquiring Funds are new with no performance history. Alternatively, revise this disclosure as appropriate.
Response: The Trust responds by revising each referenced instance to state that each Target Fund is the accounting survivor of its proposed reorganization.
If you have any questions or require further information, please contact John Hadermayer at (262) 318-8236 or jhadermayer@tidalfg.com.
Sincerely,
/s/ John Hadermayer
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CORRESP
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Tidal ETF Trust
234 West Florida Street, Suite 203
Milwaukee, Wisconsin 53204
September 24, 2024
VIA EDGAR TRANSMISSION
Mr. Tony Burak
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Tidal ETF Trust (the “Trust”)
Form N-14
File No. 333-281819
Dear Mr. Burak:
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 September
23, 2024, with respect to the Form N-14 Proxy Statement and Prospectus (the “N-14”) regarding the proposed reorganization
of the Unusual Whales Subversive Democratic Trading ETF and the Unusual Whales Subversive Republican Trading ETF (“Target Funds”),
each a series of Series Portfolios Trust (the “SPT”), into the Unusual Whales Subversive Democratic Trading ETF and the Unusual
Whales Subversive Republican Trading ETF, respectively (“Acquiring Funds”), each a newly created series of the Trust.
Capitalized terms not otherwise defined have the
same meaning as in the filing.
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 filing.
1. On page 5 and page 30 of the proxy statement/prospectus, it states that each Acquiring Fund is the accounting survivor of its proposed
reorganization. Please explain supplementally how this is correct if the Acquiring Funds are new with no performance history. Alternatively,
revise this disclosure as appropriate.
Response: The Trust responds by revising
each referenced instance to state that each Target Fund is the accounting survivor of its proposed reorganization.
If you have any questions or require further information,
please contact John Hadermayer at (262) 318-8236 or jhadermayer@tidalfg.com.
Sincerely,
/s/ John Hadermayer
John Hadermayer
SVP Legal
Tidal Investments LLC
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