Correspondence 0000051931-25-000032 from Capital Group Equity ETF Trust I (CIK 0002034928)
Capital Group Equity ETF Trust I (CIK 0002034928)
Date: Jan. 8, 2025 · CIK: 0002034928 · Accession: 0000051931-25-000032
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File numbers found in text: 333-281924, 811-24000
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CORRESP
1
filename1.htm
The
Capital Group Companies, Inc.
333 South Hope Street
Los Angeles, California 90071-1406
January 8, 2025
Soo Im-Tang
U.S. Securities
and Exchange Commission
Division of Investment
Management
Disclosure Review
Office
100 F Street, N.E.
Washington, D.C.
20549-3628
Re:
Capital Group U.S. Small and Mid
Cap ETF (“US SMID”)
Initial
Registration Statement on Form N-1A
File
Nos. 333-281924, 811-24000
Dear Ms. Im-Tang:
In response to
your comments provided on December 10, 2024 to the Pre-Effective Amendment No. 1 to the registration statement on Form N-1A (the “Registration
Statement”) of Capital Group Equity ETF Trust I, which includes as its sole series, US SMID (the “Fund”), we hereby
file Pre-Effective Amendment No. 2 to the Registration Statement under the Investment Company Act of 1940 (the “1940 Act”)
(such amendment, the “Amendment”) pursuant to Rule 472 of the 1933 Act. We appreciate your prompt response to the filing.
Our
responses to your comments are set forth below.
General
1. Section 2.11(a)
of the Declaration of Trust states that no shareholder of a series or a class may maintain
a derivative action on behalf of the trust with respect to such series or class unless holders
of at least twenty percent (20%) of the outstanding shares of such series or class join in
the bringing of such action. Section 2.11(b) of the Declaration of Trust states that the
trustees may require shareholders making a pre-suit demand to reimburse the trust for the
expense of any advisers the trustees retain to investigate the demand in the event that the
trustees determine not to bring an action. Please disclose in an appropriate location in
the prospectus these provisions and that these provisions do not apply to claims arising
under federal securities laws.
Response:
Please refer to the heading “Derivative actions” in the section entitled “Shareholder information” in the
prospectus, which includes the following disclosure:
Derivative
actions The trust’s declaration of trust provides a process for the bringing of derivative actions by shareholders.
Except for claims under federal securities laws, no shareholder may maintain a derivative action on behalf of the fund
unless holders of at least 20% of the outstanding shares of the fund join in bringing such action. Prior to bringing a derivative action,
a demand by the complaining shareholder must first be made on the trustees. Following receipt of the demand, the trustees must be afforded
a reasonable amount of time to consider and investigate the demand. The trustees will be entitled to retain counsel or other advisers
in considering the merits of the request and, except for claims under federal securities laws, the trustees may require an undertaking
by the shareholders making such request to reimburse the fund for the expense of any such advisers in the event that the trustees determine
not to bring such action.
We believe
the existing disclosure is responsive to the comment.
Prospectus
Principal
Investment Strategies, Page 1
2. The information
for the market capitalization of the largest companies included in the Russell 2500 Index
and the Russell Midcap Index is as of July 1, 2024. Please provide the information for the
market capitalization of the largest companies included in such indices as of a more recent
date.
Response:
The Russell indices are reconstituted annually in June. Accordingly, the information for the market capitalization of the largest
companies is accurate as of the proposed effective date of the Registration Statement.
Thank you
for your consideration of our responses to your comments. If you have any questions, please do not hesitate to contact us.
Sincerely,
/s/
Joshua R. Diggs
Joshua
R. Diggs
Counsel
(213) 615-0047
josh.diggs@capgroup.com