SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

Correspondence 0001999371-24-007878 from Kurv ETF Trust (CIK 0001782952)

Kurv ETF Trust (CIK 0001782952)
Date: June 27, 2024 · CIK: 0001782952 · Accession: 0001999371-24-007878

AI Filing Summary & Sentiment

File numbers found in text: 333-233633, 811-23473

Date
June 27, 2024
Author
/s/ David J. Baum
Form
CORRESP
Company
Kurv ETF Trust (CIK 0001782952)

Letter

The Atlantic Building

950 F Street, NW

Washington, DC 20004-1404

202-239-3300 | Fax: 202-239-3333

David J. Baum Direct Dial: 202-239-3346 Email: David.Baum@alston.com

June 27, 2024

VIA E-mail and EDGAR

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Christopher Bellacicco

Re:

Kurv ETF Trust (the “Trust” or “Registrant”)

Post-Effective Amendment No. 12 to the Trust’s Registration Statement on Form N-1A, filed on March 22, 2024

File Numbers 333-233633, 811-23473

Ladies and Gentlemen:

This letter is in response to the supplemental comments provided by the staff of the U.S. Securities and Exchange Commission (the “Staff”) by phone (the “Comments”) on June 27, 2024, relating to Post-Effective Amendment No. 12 (“PEA No. 12”) to the Trust’s Registration Statement on Form N-1A filed on April 9, 2024, regarding the Kurv Yield Premium Technology Select ETF (now known as the Kurv Technology Titans Select ETF) (the “Fund”), a series of the Trust, and the response letter to the Staff’s comments on PEA No. 12 dated June 20, 2024 (the “June 20 Comment Response Letter”). The prospectus (the “Prospectus”) and statement of additional information (“SAI,” and together with the Prospectus, the “Documents”) contained in the Registration Statement will be updated in response to the Staff’s Comments and a revised post-effective amendment to the Registration Statement reflecting these changes will be filed subsequent to this correspondence.

Prospectus

Summary Section – Principal Investment Strategies

Comment #1

The Response to Comment #4 in the June 20 Comment Response Letter notes, under “Cash and/or Synthetic Long Exposure,” that “[t]he notional exposure to an underlying company will not exceed 150% of net asset value.” The Staff further notes that in the third bullet point in the response to Comment #19 in the June 20 Comment Response Letter, it states that “the combination of the purchased call options and the sold put options provides each Underlying Kurv Yield Premium ETF with investment exposure equal to approximately 100% of Underlying Security for the duration of the applicable options exposure.” Please clarify where the Fund will and will not use 150% notional exposure.

Alston & Bird LLP www.alston.com

Atlanta | Beijing | Brussels | Charlotte | Dallas | Los Angeles | New York | Research Triangle | San Francisco | Silicon Valley | Washington, D.C.

June 27, 2024

Page 2

Response #1

The Registrant note that the Fund will only have notional exposure to an underlying company of up to 150% of net asset value when the Fund buys call options and sells put options directly. When the Fund gains exposure to an underlying company through an Underlying Kurv Yield Premium ETF, notional exposure to the underlying company would be limited to 100% of net asset value. The Registrant has clarified the disclosure in response to the comment. Please the revised disclosure below:

Cash and/or Synthetic Long Exposure

The Fund may gain long exposure via purchasing shares of individual companies or creating a synthetic long position. To achieve a synthetic long exposure, the Fund buys call options of a technology company and, simultaneously, sells put options of the same company to try to replicate the price movements of underlying company. The combination of the long call options and sold put options seek to provide the Fund with investment exposure to the underlying company for the duration of the application option exposure. The notional exposure to an underlying company when the Fund buys put and call options directly will not exceed 150% of net asset value (when obtaining exposure to an underlying company through an Underlying Kurv Yield Premium ETF, notional exposure will be limited to 100% of net asset value). The call options the Fund buys and the put options it sells will be at the same strike price and have the same expiration, however, the amount may differ.

Comment #2

The Response to Comment #4 in the June 20 Comment Response Letter contains a reference to “Underlying Security” in the second to last line of the first paragraph under “Underlying Kurv Yield Premium ETF’s Return Profile vs Underlying Security.” Please verify if “Underlying Security” is the correct term here or if it should say “Underlying Kurv Yield Premium ETF.”

Response #2

The Registrant confirms that the reference should be to “Underlying Kurv Yield Premium ETF” and has revised the disclosure accordingly.

***

If you have any further questions, comments or informational requests relating to this matter, please do not hesitate to contact me at (202) 239-3346.

Sincerely,
/s/ David J. Baum

Show Raw Text
CORRESP
1
filename1.htm

The Atlantic Building

950 F Street, NW

Washington, DC 20004-1404

202-239-3300 | Fax: 202-239-3333

    David J. Baum
    Direct Dial:  202-239-3346
    Email:  David.Baum@alston.com

June 27, 2024

VIA E-mail and EDGAR

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Christopher Bellacicco

    Re:

    Kurv ETF Trust (the “Trust” or “Registrant”)

    Post-Effective Amendment No. 12 to the Trust’s
    Registration Statement on Form N-1A, filed on March 22, 2024

    File Numbers 333-233633, 811-23473

Ladies and Gentlemen:

This letter is in response
to the supplemental comments provided by the staff of the U.S. Securities and Exchange Commission (the “Staff”) by phone (the
“Comments”) on June 27, 2024, relating to Post-Effective Amendment No. 12 (“PEA No. 12”) to the Trust’s
Registration Statement on Form N-1A filed on April 9, 2024, regarding the Kurv Yield Premium Technology Select ETF (now known as the Kurv
Technology Titans Select ETF) (the “Fund”), a series of the Trust, and the response letter to the Staff’s comments on
PEA No. 12 dated June 20, 2024 (the “June 20 Comment Response Letter”). The prospectus (the “Prospectus”) and
statement of additional information (“SAI,” and together with the Prospectus, the “Documents”) contained in the
Registration Statement will be updated in response to the Staff’s Comments and a revised post-effective amendment to the Registration
Statement reflecting these changes will be filed subsequent to this correspondence.

Prospectus

Summary Section – Principal Investment
Strategies

Comment #1

The Response to Comment
#4 in the June 20 Comment Response Letter notes, under “Cash and/or Synthetic Long Exposure,” that “[t]he notional exposure
to an underlying company will not exceed 150% of net asset value.” The Staff further notes that in the third bullet point in the
response to Comment #19 in the June 20 Comment Response Letter, it states that “the combination of the purchased call options and
the sold put options provides each Underlying Kurv Yield Premium ETF with investment exposure equal to approximately 100% of Underlying
Security for the duration of the applicable options exposure.” Please clarify where the Fund will and will not use 150% notional
exposure.

  Alston & Bird LLP
  www.alston.com

Atlanta | Beijing
| Brussels | Charlotte | Dallas | Los Angeles | New York | Research Triangle | San Francisco | Silicon Valley | Washington, D.C.

June 27, 2024

Page 2

Response #1

The Registrant note that the Fund will only
have notional exposure to an underlying company of up to 150% of net asset value when the Fund buys call options and sells put options
directly. When the Fund gains exposure to an underlying company through an Underlying Kurv Yield Premium ETF, notional exposure to the
underlying company would be limited to 100% of net asset value. The Registrant has clarified the disclosure in response to the comment.
Please the revised disclosure below:

Cash and/or Synthetic Long Exposure

The Fund may gain long exposure via
purchasing shares of individual companies or creating a synthetic long position. To achieve a synthetic long exposure, the Fund buys call
options of a technology company and, simultaneously, sells put options of the same company to try to replicate the price movements of
underlying company. The combination of the long call options and sold put options seek to provide the Fund with investment exposure to
the underlying company for the duration of the application option exposure. The notional exposure to an underlying company when
the Fund buys put and call options directly will not exceed 150% of net asset value (when
obtaining exposure to an underlying company through an Underlying Kurv Yield Premium ETF, notional exposure will be limited to 100% of
net asset value). The call options the Fund buys and the put options it sells will be at the same strike price and have
the same expiration, however, the amount may differ.

Comment #2

The Response to Comment #4 in the June 20 Comment Response
Letter contains a reference to “Underlying Security” in the second to last line of the first paragraph under “Underlying
Kurv Yield Premium ETF’s Return Profile vs Underlying Security.” Please verify if “Underlying Security” is the
correct term here or if it should say “Underlying Kurv Yield Premium ETF.”

Response #2

The Registrant confirms that the reference should
be to “Underlying Kurv Yield Premium ETF” and has revised the disclosure accordingly.

***

If you have any further
questions, comments or informational requests relating to this matter, please do not hesitate to contact me at (202) 239-3346.

  Sincerely,

  /s/ David J. Baum

  David J. Baum