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Correspondence 0001999371-25-008203 from ETF Opportunities Trust (CIK 0001771146)

ETF Opportunities Trust (CIK 0001771146)
Date: June 24, 2025 · CIK: 0001771146 · Accession: 0001999371-25-008203

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File numbers found in text: 333-234544, 811-23439

Date
June 24, 2025
Author
/s/ John H. Lively
Form
CORRESP
Company
ETF Opportunities Trust (CIK 0001771146)

Letter

JOHN H. LIVELY, Managing Partner john.lively@practus.com 11300 Tomahawk Creek Pkwy., Suite 310 Leawood, KS 66211 (913) 660-0778 June 24, 2025 Ms. Christina DiAngelo Fettig Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549

Re: ETF Opportunities Trust (File Nos. 333-234544 and 811-23439)

Dear SEC Staff:

This letter provides the responses of ETF Opportunities Trust (the "Trust" or the "Registrant") to the additional accounting comments of the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission") that you provided to Practus, LLP on June 24, 2025. The comments related to the N-14 of the Trust, which was filed on April 10, 2025, under the Securities Act of 1933, as amended. The N-14 was filed to reorganize the OTG Latin America Fund (the "Fund"), a series of World Funds Trust (the "Trust"), into a new series of the Trust, the OTG Latin America ETF (the "ETF"). For your convenience, I have summarized the comments in this letter and provided the Trust's response below each comment. Capitalized terms not defined in this letter shall have the same meaning ascribed to such term in the N-14.

Accounting Comments

1. Comment : The Staff disagrees with the categorization of the expenses associated with the proposed reorganization as extraordinary expenses.

Response : The Trust acknowledges the Staff's statement and disagrees with the Staff's view.

* * *

Please contact me at (913) 660-0778 regarding the responses contained in this letter.

Sincerely,
/s/ John H. Lively

Show Raw Text
CORRESP
 1
 filename1.htm

 JOHN H. LIVELY, Managing Partner
john.lively@practus.com
11300 Tomahawk Creek Pkwy., Suite 310
Leawood, KS 66211
(913) 660-0778

 June 24, 2025

 Ms. Christina DiAngelo Fettig
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

 Re: ETF Opportunities Trust (File Nos. 333-234544 and 811-23439)

 Dear SEC Staff:

 This letter provides the responses
of ETF Opportunities Trust (the "Trust" or the "Registrant") to the additional accounting comments of the staff
(the "Staff") of the U.S. Securities and Exchange Commission (the "Commission") that you provided to Practus,
LLP on June 24, 2025. The comments related to the N-14 of the Trust, which was filed on April 10, 2025, under the Securities Act of 1933,
as amended. The N-14 was filed to reorganize the OTG Latin America Fund (the "Fund"), a series of World Funds Trust (the "Trust"),
into a new series of the Trust, the OTG Latin America ETF (the "ETF"). For your convenience, I have summarized the comments
in this letter and provided the Trust's response below each comment. Capitalized terms not defined in this letter shall have the
same meaning ascribed to such term in the N-14.

 Accounting
Comments

 1. Comment : The Staff disagrees with the categorization
of the expenses associated with the proposed reorganization as extraordinary expenses.

 Response :
The Trust acknowledges the Staff's statement and disagrees with the Staff's view.

 * * *

 Please contact me at (913)
660-0778 regarding the responses contained in this letter.

 Sincerely,

 /s/ John H. Lively

 John H. Lively