Correspondence 0001398344-25-000833 from Roundhill ETF Trust (CIK 0001976517)
Roundhill ETF Trust (CIK 0001976517)
Date: Jan. 21, 2025 · CIK: 0001976517 · Accession: 0001398344-25-000833
AI Filing Summary & Sentiment
File numbers found in text: 333-273052, 811-23887
Letter
VIA EDGAR CORRESPONDENCE United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Roundhill ETF Trust File Nos. 333-273052; 811-23887
Dear Ms. Smiley:
This letter responds to your additional comments regarding the registration statement filed on Form N-1A for the Roundhill ETF Trust (the “Registrant” or the “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”) on September 20, 2024 (the “Registration Statement”). The Registration Statement relates to the Roundhill Weekly T-Bill ETF (the “Fund”), a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement. References to the “Prior Correspondence Letter” refer to the initial correspondence letter filed with the Staff on January 16, 2025.
Comment 1 – General
The Staff refers to the Registrant’s Response to Comment 11 set forth in the Prior Correspondence Letter. While it may be used as a secondary index, the Staff believes that the Solactive Global Developed Government Bond TR USD Index is not an appropriate broad-based index for the Fund, as it does not represent the applicable debt market (i.e., it includes non-U.S. government bonds) and is a global index, whereas the Fund only invests in U.S. Treasury Bills. Please inform the Staff of the different broad-based index that the Fund intends to use.
Response to Comment 1
The Registrant confirms that the Fund will use an appropriate broad-based index.
* * * * * * * *
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
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CORRESP
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Morrison Warren
Partner
Chapman and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T (312) 845-3484
warren@chapman.com
January 21, 2025
VIA EDGAR CORRESPONDENCE
Eileen Smiley
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Roundhill ETF Trust
File Nos. 333-273052; 811-23887
Dear Ms. Smiley:
This letter responds to
your additional comments regarding the registration statement filed on Form N-1A for the Roundhill ETF Trust (the “Registrant”
or the “Trust”) with the staff of the Securities and Exchange Commission (the “Staff”) on September
20, 2024 (the “Registration Statement”). The Registration Statement relates to the Roundhill Weekly T-Bill ETF (the
“Fund”), a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed
to them in the Registration Statement. References to the “Prior Correspondence Letter” refer to the initial correspondence
letter filed with the Staff on January 16, 2025.
Comment
1 – General
The Staff refers to the
Registrant’s Response to Comment 11 set forth in the Prior Correspondence Letter. While it may be used as a secondary index, the
Staff believes that the Solactive Global Developed Government Bond TR USD Index is not an appropriate broad-based index for the Fund,
as it does not represent the applicable debt market (i.e., it includes non-U.S. government bonds) and is a global index, whereas
the Fund only invests in U.S. Treasury Bills. Please inform the Staff of the different broad-based index that the Fund intends to use.
Response
to Comment 1
The Registrant confirms
that the Fund will use an appropriate broad-based index.
* * * * * * * *
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
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