SEC Company Response from Tidal Trust II (CIK 0001924868) — Nov 20, 2025
Tidal Trust II (CIK 0001924868)
Date: Nov. 20, 2025 · CIK: 0001924868 · Accession: 0001999371-25-018256
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File numbers found in text: 333-264478, 811-23793
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CORRESP
1
filename1.htm
Tidal
Trust II
234
West Florida Street, Suite 203
Milwaukee,
Wisconsin 53204
November
20, 2025
VIA
EDGAR TRANSMISSION
Christopher
R. Bellacicco, Senior Counsel
U.S.
Securities and Exchange Commission
Division
of Investment Management
100
F Street NE
Washington,
DC 20549
Re: Tidal
Trust II (the “Trust”)
Post-Effective Amendment No. 424 to the Trust’s Registration
Statement on Form N-1A (the “Amendment”)
File
Nos. 811-23793; 333-264478
Dear
Mr. Bellacicco:
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 November 20, 2025, with respect to the Registration Statement for the Trust’s proposed new
series, Defiance QTUM Options Income ETF (the “Fund”). 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 Registration Statement.
1. The
Staff notes that it has previously provided comments on similar Trust filings regarding the
description of certain options strategies and the potential for these strategies to generate
return of capital distributions. Please confirm that, to the extent applicable, revisions
will be made to this filing that are in conformance with disclosures made for similar Trust
filings in response to the Staff’s comments on this matter.
Response:
The Trust responds by confirming that such conforming revisions have been made as provided to the Staff under separate cover.
2. The
Trust notes that the Item 9 disclosure indicates the Fund may purchase options, in addition
to selling options. However, the Item 4 disclosure only discusses the Fund’s ability
to sell options. Please revise the Item 4 disclosure to disclose the Fund’s ability
to purchase options.
Response:
The Trust responds by confirming that such revisions have been made as provided to the Staff under separate cover.
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
of Legal Services
Tidal
Investments LLC