Correspondence 0001398344-24-005027 from Roundhill ETF Trust (CIK 0001976517)
Roundhill ETF Trust (CIK 0001976517)
Date: March 1, 2024 · CIK: 0001976517 · Accession: 0001398344-24-005027
AI Filing Summary & Sentiment
File numbers found in text: 333-273052, 811-23887
Referenced dates: February 14, 2024
Letter
VIA EDGAR CORRESPONDENCE United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Roundhill ETF Trust (the “Trust”) File Nos. 333-273052; 811-23887
Dear Mr. Brodsky:
This letter responds to your comments regarding the registration statement filed on Form N-1A for Roundhill ETF Trust (the “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”) on December 15, 2023 (the “Registration Statement”). The Registration Statement relate to the Roundhill Daily 2X Long Magnificent Seven ETF, Roundhill Daily Inverse Magnificent Seven ETF and the Roundhill Daily 2X Inverse Magnificent Seven ETF (each, a “Fund” and together, the “Funds”), each a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statements. To the extent that a comment is applicable to both Funds, it has been applied accordingly.
Comment 1 – General
The Staff asks for additional clarification regarding the Registrant’s response to Comment #5 in its prior correspondence dated February 14, 2024. Beyond a wholly-owned subsidiary, please supplementally explain to the Staff if the Funds will primarily control any entity that primarily engages in investment activities in securities or other assets.
Response to Comment 1
Pursuant to the Staff’s comment, the Registrant confirms that the Funds have no current intention to engage in investment activities in securities or other assets through any entity that the Funds maintain any control over whatsoever.
* * * * * * * *
Please call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely
yours,
Chapman
and Cutler LLP
Show Raw Text
CORRESP
1
filename1.htm
Morrison
Warren
Partner
Chapman
and Cutler LLP
320
South Canal Street, 27th Floor
Chicago,
Illinois 60606
T
(312) 845-3484
warren@chapman.com
March
1, 2024
VIA
EDGAR CORRESPONDENCE
Aaron
Brodsky
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Roundhill
ETF Trust (the “Trust”)
File
Nos. 333-273052; 811-23887
Dear
Mr. Brodsky:
This
letter responds to your comments regarding the registration statement filed on Form N-1A for Roundhill ETF Trust (the “Trust”)
with the staff of the Securities and Exchange Commission (the “Staff”) on December 15, 2023 (the “Registration
Statement”). The Registration Statement relate to the Roundhill Daily 2X Long Magnificent Seven ETF, Roundhill Daily
Inverse Magnificent Seven ETF and the Roundhill Daily 2X Inverse Magnificent Seven ETF (each, a “Fund” and
together, the “Funds”), each a series of the Trust. Capitalized terms used herein, but not otherwise defined,
have the meanings ascribed to them in the Registration Statements. To the extent that a comment is applicable to both Funds, it
has been applied accordingly.
Comment
1 – General
The
Staff asks for additional clarification regarding the Registrant’s response to Comment #5 in its prior correspondence dated
February 14, 2024. Beyond a wholly-owned subsidiary, please supplementally explain to the Staff if the Funds will primarily control
any entity that primarily engages in investment activities in securities or other assets.
Response
to Comment 1
Pursuant
to the Staff’s comment, the Registrant confirms that the Funds have no current intention to engage in investment activities
in securities or other assets through any entity that the Funds maintain any control over whatsoever.
*
* * * * * * *
Please
call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely
yours,
Chapman
and Cutler LLP
By:
/s/
Morrison C. Warren
Morrison
C. Warren
cc:
Richard
Coyle, Esq., Chapman and Cutler LLP
2
Exhibit
A
Roundhill
Daily 2X Long Magnificent Seven ETF
Fees
and Expenses of the Fund
The
table below describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Fund Shares”).
You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in
the table and Example below.
Annual
Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Management
Fees(1)
0.95%
Distribution
and Service (12b-1) Fees
0.00%
Other
Expenses(2)
0.00%
Acquired
Fund Fees and Expenses(2)
0.18%
Total
Annual Fund Operating Expenses
1.13%
(1) The
investment advisory agreement between the Trust and Roundhill Financial Inc. (“Roundhill”)
utilizes a unitary fee arrangement pursuant to which Roundhill will pay all operating
expenses of the Fund, except Roundhill’s management fees, interest charges on any
borrowings (including net interest expenses incurred in connection with an investment
in reverse repurchase agreements or futures contracts), dividends and other expenses
on securities sold short, taxes, brokerage commissions and other expenses incurred in
placing orders for the purchase and sale of securities and other investment instruments
(including any net account or similar fees charged by futures commission merchants),
accrued deferred tax liability and extraordinary expenses.
(2) “Other
Expenses” and “Acquired Fund Fees and Expenses” are estimates based
on the expenses the Fund expects to incur for the current fiscal year.
Example
This
example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The example
assumes that you invest $10,000 in the Fund for the time periods indicated, and then sell all of your Fund Shares at the end of
those periods. The example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses
remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
Year
1
Year
3
$119
$338
Exhibit
B
Roundhill
Daily 2X Inverse Magnificent Seven ETF
Fees
and Expenses of the Fund
The
table below describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Fund Shares”).
You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in
the table and Example below.
Annual
Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Management
Fees(1)
0.95%
Distribution
and Service (12b-1) Fees
0.00%
Other
Expenses(2)
0.00%
Total
Annual Fund Operating Expenses
0.95%
(1) The
investment advisory agreement between the Trust and Roundhill Financial Inc. (“Roundhill”)
utilizes a unitary fee arrangement pursuant to which Roundhill will pay all operating
expenses of the Fund, except Roundhill’s management fees, interest charges on any
borrowings (including net interest expenses incurred in connection with an investment
in reverse repurchase agreements or futures contracts), dividends and other expenses
on securities sold short, taxes, brokerage commissions and other expenses incurred in
placing orders for the purchase and sale of securities and other investment instruments
(including any net account or similar fees charged by futures commission merchants),
accrued deferred tax liability and extraordinary expenses.
(2) “Other
Expenses” are estimates based on the expenses the Fund expects to incur for the
current fiscal year.
Example
This
example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The example
assumes that you invest $10,000 in the Fund for the time periods indicated, and then sell all of your Fund Shares at the end of
those periods. The example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses
remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
Year
1
Year
3
$100
$327
Exhibit
C
Roundhill
Daily Inverse Magnificent Seven ETF
Fees
and Expenses of the Fund
The
table below describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Fund Shares”).
You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in
the table and Example below.
Annual
Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)
Management
Fees(1)
0.95%
Distribution
and Service (12b-1) Fees
0.00%
Other
Expenses(2)
0.00%
Total
Annual Fund Operating Expenses
0.95%
(1) The
investment advisory agreement between the Trust and Roundhill Financial Inc. (“Roundhill”)
utilizes a unitary fee arrangement pursuant to which Roundhill will pay all operating
expenses of the Fund, except Roundhill’s management fees, interest charges on any
borrowings (including net interest expenses incurred in connection with an investment
in reverse repurchase agreements or futures contracts), dividends and other expenses
on securities sold short, taxes, brokerage commissions and other expenses incurred in
placing orders for the purchase and sale of securities and other investment instruments
(including any net account or similar fees charged by futures commission merchants),
accrued deferred tax liability and extraordinary expenses.
(2) “Other
Expenses” are estimates based on the expenses the Fund expects to incur for the
current fiscal year.
Example
This
example is intended to help you compare the cost of investing in the Fund with the cost of investing in other funds. The example
assumes that you invest $10,000 in the Fund for the time periods indicated, and then sell all of your Fund Shares at the end of
those periods. The example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses
remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
Year
1
Year
3
$100
$327