SEC Company Response from Tidal Trust IV (CIK 0002043390) — Oct 17, 2025
Tidal Trust IV (CIK 0002043390)
Date: Oct. 17, 2025 · CIK: 0002043390 · Accession: 0001999371-25-015643
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Tidal Trust IV
234 West Florida Street, Suite 203
Milwaukee, Wisconsin 53204
October 17, 2025
VIA EDGAR TRANSMISSION
Ms. Elizabeth Goody
Division of Investment Management, Disclosure Review Office
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Tidal Trust IV (the
“Trust”)
Post-Effective Amendment No. 2 to the Trust’s Registration Statement on Form N-1A (the
“Amendment”)
File Nos. 811- 24061; 333- 285633
Dear Ms. Goody:
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 September 25, 2025, with respect to Portfolio Building Block European Banks Index ETF, Portfolio Building Block World Pharma and Biotech
Index ETF, and Portfolio Building Block Integrated Oil and Gas and Exploration and Production Index ETF (each, a “Fund,” and
together, the ‘Funds”). 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.
Prospectus
1. With respect to the Portfolio Building Block European Banks Index ETF,
in the Principal Investment Strategies section, in the discussion of Index eligibility criteria, please clarify whether to be eligible
for inclusion in the Index, as suggested by the Fund’s name, banking companies themselves must be European companies versus European
issuers.
Response: The Trust has revised
the relevant eligibility criteria disclosure to clarify that to be eligible for inclusion in the Index, a company’s shares must
be publicly listed on one of the European countries and exchanges listed in the Index eligibility criteria section of the prospectus.
2. For each Fund, in the Principal Investment Strategies section following
the anticipated range of constituents in the Index, please also disclose the specific number of constituents in the Index as of a recent
practicable date.
Response: The Trust has added the requested disclosure
that as of the market close of October 9, 2025, each index has the following number of constituents:
· BITA European Banks Index:
60 Constituents
· BITA World Pharmaceuticals &
Biotech Index: 68 Constituents
· BITA Oil & Gas Exploration
& Production Ecosystem Index: 46 Constituents
3. For each Fund, in the Principal Investment Risks, please supplement
the Index Strategy Risk disclosure to also address the variability in the number of Index constituents, in particular how
the number of constituents may impact the Funds
concentration of investments and ability to track the Index.
Response: As requested, the Trust
has supplemented the Index Strategy Risk to note that the number of constituents in the Index will vary over time and may contribute to
concentration risk and tracking error risk, which are disclosed in separate principal risk factors in each Fund’s prospectus.
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4. For each Fund, in the Principal Investment Risks, consistent with relevant
instructions to Item 4(b)(ii) of Form N-1A, please add disclosure that, “[a]n investment in the Fund is not a deposit of the bank
and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.”
Response: The Trust respectfully
notes that, consistent with relevant instructions to Item 4(b)(ii) of Form N-1A, the Funds are neither money market funds nor advised
by or sold through an insured depository institution. Accordingly, the Funds are not required to (and therefore respectfully decline to)
include the FDIC-related disclosure suggested in this comment.
5. With respect to the Portfolio Building Block European Banks Index ETF,
in the Principal Investment Risks section, please consider whether Developed Markets Risk is also a principal risk for this Fund.
Response: The Trust has added Developed
Markets Risk is also a principal risk for this Fund.
6. For each Fund, in the Principal Investment Strategies section with respect
to the disclosure related to each Index being reconstituted quarterly, we note that the Index constituents are weighted according to their
free float market capitalization. For each Index:
i. please supplementally tell us whether any particular issuer will make
up more than 10% of the Index.
ii. And, if so, please supplementally tell us which issuer(s) and the percentage
of the Index such issuers represent as of a recent practicable date; and
Response: Yes, as of market close
October 9, 2025, each Fund’s Index has one or two constituents that makes up more than 10% of the relevant Index, as described below.
In addition, the Trust notes that the Index methodology is designed to prevent excessive concentration, as described below.
BITA World Pharmaceuticals & Biotech
Index (BWBLSI)
As of the market close of October 9th,
2025, the following securities in the BITA World Pharmaceuticals & Biotech Index (BWBLSI), represent more than or are close to 10%
of the index weight:
ISIN
Ticker
Name
Weight
US5324571083
LLY
ELI LILLY & CO
14.13%
US4781601046
JNJ
JOHNSON & JOHNSON
8.95%
The Trust also notes that this Index methodology
is designed to prevent excessive concentration in a particular issuer or issuers. Specifically, the Index applies the following capping
constraints at the issuer level:
· No single issuer may exceed
25% of the Index weight.
· Additionally, all issuers with
individual weights above 4.5% may not, in the aggregate, exceed 45% of the total Index weight.
These capping rules are applied at each
quarterly determination date.
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BITA Oil & Gas Exploration &
Production Ecosystem Index (BOGEPI)
As of the market close of October 9th,
2025, the following securities in the BITA Oil & Gas Exploration & Production Ecosystem Index (BOGEPI), represent more than or
are close to 10% of the index weight:
ISIN
Ticker
Name
Weight
US30231G1022
XOM
EXXON MOBIL CORP
18.47%
US1667641005
CVX
CHEVRON CORP
11.88%
The Trust also notes that this Index methodology
is designed to prevent excessive concentration in a particular issuer or issuers. Specifically, the Index applies the following capping
constraints at the issuer level:
· No single issuer may exceed
25% of the Index weight.
· Additionally, all issuers with
individual weights above 4.5% may not, in the aggregate, exceed 45% of the total Index weight.
These capping rules are applied at each
quarterly determination date.
BITA European Banks Index (BEURBI)
As of the market close of October 9th,
2025, the following securities in the BITA European Banks Index (BEURBI) represent more than or are close to 10% of the index weight:
ISIN
Ticker
Name
Weight
GB0005405286
HSBA
HSBC HOLDINGS PLC
13.50%
The Trust also notes that this Index methodology
is designed to prevent excessive concentration in a particular issuer or issuers. Specifically, the Index applies the following capping
constraints at the issuer level:
· No single issuer may exceed
25% of the Index weight.
· Additionally, all issuers with
individual weights above 4.5% may not, in the aggregate, exceed 45% of the total Index weight.
These capping rules are applied at each
quarterly determination date.
iii. Depending on your response, please supplementally tell us how you have
considered the appropriateness of the disclosure given the significant exposure to such Issuer(s).
Response: The Trust
has added further disclosure to the Index methodology discussion in each Fund’s Principal Investment Strategies section, describing
that the Index methodology includes the capping constraints (described in the response above) to limit the amount that an issuer or issuers
can make up of the Index. Upon consideration, the Trust believes that this revised disclosure together with the existing strategy and
risk disclosure, including concentration risk and non-diversification risk, accurately and appropriately discloses materially relevant
information to shareholders and investors.
7. For each Fund, in the Principal Investment Risks, as applicable,
please supplement the Developed Markets Risk disclosure to also address the variability in the number of Index constituents, in particular how the number of constituents
may impact the Funds concentration of investments and ability to track the Index.
Response: The Trust has enhanced
the developed markets risk to discuss that Fund’s concentration risk is increased by the facts the Fund seeks to track the performance
of the Index and the Index is exclusively comprised of a varying number of constituents in developed markets that meet the Index’s
eligibility criteria.
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8. For the Portfolio Building Block Integrated Oil and Gas and Exploration
and Production Index ETF, in the Principal Investment Risks section, please consider supplementing the Oil and Gas Industry Risk disclosure
to also address risks associated with oil and gas extraction activities.
Response: As requested, the Trust
has enhanced the Oil and Gas Industry Risk factors to also address risks associated with oil and gas extraction activities.
9. For each Fund, related to Principal Investment Risks disclosure, please
consider wither the Management Risk disclosed in Item 9 of Form N-1A section should also be disclosed in Item 4 section or otherwise revised.
Response: The Trust respectfully
notes that because each Fund uses a “passive management” (or indexing) approach to portfolio management, the current Index
Strategy Risk and Passive Investment Risk factors included in each Fund’s Item 4 and 9 principal investment risks sections appropriately
address relevant management risks for the Funds. Accordingly, the Trust has removed the separate Management Risk factor that was previously
included in Item 9 disclosure.
If you have any questions or require further information,
please contact Jonathan R. Massey at (262) 226-4032 or jmassey@tidalfg.com.
Sincerely,
/s/ Jonathan R. Massey
Jonathan R. Massey
SVP of Legal Services
Tidal Investments LLC
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