SecProbe.io

CORRESP
1
filename1.htm

            Stradley Ronon Stevens & Young, LLP

            2005 Market Street, Suite 2600

            Philadelphia, PA 19103

            Telephone  215.564.8000

            Fax  215.564.8120

            www.stradley.com

    J. Stephen Feinour, Jr.

    (215) 564-8521

    jfeinourjr@stradley.com

    October 23, 2024

    Filed via EDGAR

    Ms. Karen Rossotto

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549

            Subject:

            AIM ETF Products Trust (the “Trust”)

            (File Nos. 811-23504; 333-235734)

    Dear Ms. Rossotto:

    On behalf of the Trust, below are the Trust’s responses to the comments you provided with regard to Post-Effective Amendment No. 33 (the “Amendment”) to the Trust’s registration statement on Form N-1A, filed with the
      U.S. Securities and Exchange Commission (the “SEC”) on June 24, 2024 under the Investment Company Act of 1940, as amended (the “1940 Act”), and the Securities Act of 1933, as amended (the “1933 Act”).  The Amendment was filed in order to register the
      following new series of the Trust: AllianzIM 6 Month Buffer10 Allocation ETF and AllianzIM Buffer20 Allocation ETF (together, the “Funds”).

    Below we have provided your comments and the Trust’s responses. We have also included below, to the extent applicable to the Funds, comments previously provided with regard to Post-Effective Amendment No. 32 to the
      Trust’s registration statement on Form N-1A, which was filed in order to register two new series of the Trust: AllianzIM Managed Buffer10 Allocation ETF and AllianzIM Managed Buffer20 Allocation ETF (together, the “Managed Allocation FOFs”), and
      responses thereto. Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Amendment.

    General

              1.

              Comment: The SEC staff previously provided comments on the Managed Allocation FOFs. Please supplementally explain the material differences between the Funds and the Managed Allocation FOFs,
                including how you will differentiate these products for investors in communications to them.

    Response:     The Managed Allocation FOFs’ principal investment strategy employs a systematic, or managed, monthly rolling approach whereby the Managed Allocation FOF invests
      in a more limited number of AllianzIM Equity Buffer ETFs within a particular buffered strategy and “rolls” out of the

    Underlying ETF holding with less than six months remaining in its Outcome Period, as more fully described in the Managed Allocation FOFs’ registration statement.  In contrast, the Funds’ principal investment strategy
      is to hold all of the AllianzIM Equity Buffer ETFs within a particular buffered strategy in roughly equal weights (i.e., a laddered approach).  The Trust further notes that the launch of the Managed Allocation FOFs is currently being delayed and that
      both the Funds’ principal investment strategy and the Managed Allocation FOFs’ principal investment strategy are clearly described in their respective registration statements.

              2.

              Comment: The staff notes that the Fund’s name refers to Buffer10 or Buffer20, as applicable, and that the Fund’s strategy involves investing in Buffered ETFs of various dates. However, unlike the
                Buffered ETFs in which the Fund invests, the Fund does not offer a buffer; rather, the Fund’s strategy appears similar to a laddered bond strategy. Please tell us the steps you have taken or will take to avoid the potential for investor
                confusion about the Fund’s name, its strategy, and how it will perform relative to the S&P 500 Index over time. This may include potential revisions to the Fund name and/or adding bulleted disclosure similar to other defined outcome
                funds explaining how caps and buffers are likely to impact returns relative to the S&P 500 Index over time. (See, for example, the bold language in the Fund of Funds Risk on page 4 of the prospectus.) To the extent you disagree with how
                the staff characterizes the Fund in this comment, please address that in the response.

    Response:     The Trust notes that in contrast to the AllianzIM Equity Buffer ETFs in which the Funds invest (the “Underlying ETFs”), the Funds’ use of “Allocation” in their name demonstrates that the
      Funds’ strategy involves allocating assets to a set of Buffer10 or Buffer20 ETFs, as applicable. Further, the use of “Buffer10” or “Buffer20” in the Funds’ names is appropriate as it clarifies and relates to the Underlying ETFs that the Funds will
      invest in.  The Trust further notes that there are several instances throughout the prospectus clarifying that the Funds do not themselves offer a buffered strategy, and that only the Underlying ETFs offer these buffered outcomes.

              3.

              Comment: Further to Comment 2 above, because each Fund does not pursue a buffered strategy, the names “AllianzIM 6 Month Buffer10 Allocation ETF” and “AllianzIM Buffer20 Allocation ETF” are
                potentially confusing. Please delete the reference to “Buffer10” or “Buffer20,” as applicable, or identify the full suite of Underlying ETFs in the name more specifically so the context for the usage of this term is clear.

    Response:     As noted above, the Trust believes that the use of “Allocation” in the Funds’ names clearly demonstrates that Fund assets are allocated to the Underlying ETFs
      that pursue 6 Month Buffer10 or Buffer20 strategies, as applicable. Further, the use of “Buffer10” or “Buffer20” in the Funds’ names is appropriate as it clarifies and relates to the Underlying ETFs that the Funds will invest in.  The Trust also
      notes that the prospectus clearly states that the Funds do not themselves offer a buffered strategy and that only the Underlying ETFs offer these buffered outcomes.  Accordingly, the Trust believes that no changes to the Funds’ names are needed.

              4.

              Comment: Please provide completed fee tables and expense examples as attachments to your response.

    Response:     The completed fee tables and expense examples are attached hereto as Appendix A.

              5.

              Comment: Please confirm if the Underlying ETFs in which the Funds invest have been formed. Please also confirm if the Underlying ETFs are identical except with respect to their Outcome Periods.

    Response:     The Trust confirms that each Underlying ETF in which each Fund will invest is operational. The Trust further confirms that the suite of Underlying ETFs in which a
      Fund will invest is comprised of identical Underlying ETFs, except for their Outcome Periods.

    Principal Investment Strategies

              6.

              Comment: Please disclose under Principal Investment Strategies what the Underlying ETFs invest in.

    Response:     The Trust has revised the relevant section accordingly.

              7.

              Comment: Please revise the first paragraph under Principal Investment Strategies to separately discuss what the Underlying ETFs are and what they are intended to do. For example, consider moving
                the last full paragraph on page 2 to the first paragraph.

    Response:     The Trust has revised the relevant disclosure accordingly.

              8.

              Comment: The first full sentence on page 2 states: “This diversification of Outcome Periods may mitigate the risk of being unable to benefit from the Buffer, or having limited to no upside
                potential remaining to the Cap, of a single Underlying ETF due to the timing of investment in such Underlying ETF and the Underlying ETF’s price relative to the SPY ETF at that time.” Please further elaborate on this concept and please
                explain clearly how the laddered approach mitigates the risk of not achieving the intended Buffer. Consider providing an example in this section or under Additional Information about the Fund’s Principal Investment Strategies.

    Response:     Please see the response to Comment 15 below, which describes how the laddered approach to invest in multiple Underlying ETFs will yield different individual results that have an aggregate
      impact on the Fund’s portfolio. The Trust has revised the disclosure to further describe this concept.

              9.

              Comment: Please use bold text or some other means to highlight the entire third paragraph under Principal Investment Strategies.

    Response:     The Trust has reformatted the relevant disclosure accordingly.

              10.

            Comment: The third paragraph under Principal Investment Strategies states that the Fund itself does not pursue a buffered strategy. Consider clarifying, as appropriate,
              that the Fund also does not have a Cap.

    Response:     The Trust has revised the relevant disclosure.

              11.

            Comment: The last sentence of the third paragraph under Principal Investment Strategies states that the Fund’s return “may be limited to the Caps of the
              Underlying ETFs.” Consider changing “may” to “will,” if appropriate, given that the value of the Fund can’t exceed that of the Underlying ETFs.

    Response:     The Trust has revised the relevant disclosure.

              12.

            Comment: The last sentence of the paragraph above the chart in the Principal Investment

            Strategies section states that the Cap for each Underlying ETF is expected to change for each Outcome Period. Please disclose, if appropriate, that the Buffer will stay the same for each Outcome
              Period.

    Response:     The Trust has revised the relevant disclosure.

              13.

            Comment: The first paragraph on page 3 states that each Underlying ETF pursues a buffered strategy. Please elaborate on this strategy and how the Underlying
              ETFs maintain a 10% or 20% buffer, as applicable.

    Response:     The Trust has revised the relevant disclosure.

              14.

            Comment: The first and second paragraphs on page 3 of the prospectus describe the Fund in terms of what the Underlying ETFs seek (buffered market price
              performance of the SPY ETF) and in turn describes the SPY ETF in terms of price and yield performance of the S&P 500 Index. Please specifically disclose that each layer of this compound strategy seeks returns that replicate some standard
              used to measure market performance, which in turn causes increasing attenuation between the investment portfolio’s correlation and the performance standard with which investors are most likely to be familiar. Explain how the Fund’s strategy
              intends to address this ripple effect.

    Response:     The Trust believes that the prospectus clearly describes the Fund’s strategy to invest in Underlying ETFs, which in turn pursue a buffered strategy. The Trust
      notes that there are several instances in the prospectus clarifying that the Fund does not provide a buffer or cap, and the prospectus clearly discusses the strategies of the Underlying ETF to track the returns of the SPY ETF subject to a buffer and
      cap. The Trust respectfully declines to add further disclosure describing how the Fund’s returns would differ from the S&P 500 Index, as the Trust believes such discussion would contribute to investor confusion for a product that is not designed
      (and does not purport) to track the S&P 500 Index. The Trust also notes that the prospectuses for the Underlying ETFs do not include such a discussion, and believes that introducing this discussion from the perspective of the Funds (as funds of
      funds) would further contribute to investor confusion, particularly to the extent an investor in the Fund is already familiar with the strategies of the Underlying ETFs.

              15.

              Comment: The second and third sentences of the third paragraph on page 3 of the prospectus provide as follows:

                “The Fund’s laddered approach is designed to provide diversified exposure to a set of Underlying ETFs that offer upside growth potential, while still providing a level of downside
                  protection. The laddered nature of the investments in the Underlying ETFs is intended to create diversification of investment time period and market level (meaning the share price of SPY ETF at any given time) compared to investing in any
                  one Underlying ETF at any one time.”

              Please add plain English disclosure specifically explaining how the phrase “diversification of investment time period and market level” means “the share price of SPY ETF at any given time” in this context. Your staff reviewer does not
                understand the contexts in which the phrase “diversification of investment time period” would apply. Please clarify the prospectus disclosure and supplementally explain.

    Response:     This disclosure is intended to convey that the Fund will have exposure to a diverse set of

    Outcome Periods – specifically, 6 or 12 different Outcome Periods, as applicable – by investing in all 6 or all 12 Underlying ETFs at once. Accordingly, the Fund’s exposure to the outcomes sought by each Underlying ETF for its Outcome Period
      relative to the share price of SPY ETF will also be diverse. An Underlying ETF nearing the end of its Outcome Period will have different exposure and different outcomes relative to the SPY ETF than an Underlying ETF that has just reset its Outcome
      Period. For example, during periods where the SPY ETF is experiencing steady gains, the Underlying ETF nearing the end of its Outcome Period may have already reached its Cap for that Outcome Period, and so the Fund will not be able to participate in
      any further increases in the SPY ETF through that particular Underlying ETF. However, the Underlying ETF that has just reset its Outcome Period will have a new Cap based on a different Outcome NAV and will still have the potential to increase in
      value up to that Cap, and so the Fund will be able to participate in further increases in the SPY ETF through this Underlying ETF, if not the former. The same would be true on the downside via each Underlying ETF’s Buffer, which is relative to its
      Outcome NAV. By investing in all of the Underlying ETFs in a particular buffered strategy, the Fund will have multiple opportunities to participate in gains in the SPY ETF and multiple opportunities to benefit from the Buffer via the Underlying ETFs.

              16.

            Comment: The third paragraph on page 3 of the prospectus discusses the Fund’s laddered approach. Please supplementally explain if there is a risk that an
              Underlying ETF won’t operate as intended, which is why the laddered approach is needed.

    Response:     The Trust notes that the laddered approach is not designed to be a failsafe in the event an Underlying ETF does not achieve its investment objective, but rather to provide continuous exposure
      to Underlying ETFs with different Outcome Periods so an investor in the Fund is not limited to any one Cap or Buffer of a single Underlying ETF. There is a risk that an Underlying ETF won’t operate as intended, which is addressed by Investment
      Objective Risk in the Principal Investment Risks section of the prospectus. The Fund’s strategy is not intended to be a mitigating factor for an investor’s overall investment in such event, although that may be a result.

              17.

            Comment: The second sentence of the third paragraph on page 3 of the prospectus states that the Fund’s laddered approach is designed to provide diversified
              exposure to a set of Underlying E