CORRESP 1 filename1.htm




July 8, 2021

VIA EDGAR

Mr. David Manion
Division of Investment Management
Securities and Exchange Commission
100 F Street N.E.
Washington DC  20549

 
RE:
AIM Investment Securities Fund (Invesco Investment Securities Funds) (File No. 811-05686; AIM Tax-Exempt Funds (Invesco Tax-Exempt Funds (File No. 811-07890); AIM Sector Funds (Invesco Sector Funds) (File No. 811-03826); AIM Equity Funds (Invesco Equity Funds) (File No. 811-01424); AIM Investment Funds (Invesco Investment Funds) (File No. 811-05426); AIM International Mutual Funds (Invesco International Mutual Funds) (811-06463); AIM Growth Series (Invesco Growth Series) (File No. 811-02699) (each, an “OEF Registrant” and collectively, the “OEF Registrants”) and Invesco Exchange-Traded Fund Trust (File No. 811-21265); Invesco Exchange-Traded Fund Trust II (File No. 811-21977); Invesco Exchange-Traded Self-Indexed Fund Trust (File No. 811-23304); Invesco Actively Managed Exchange-Traded Fund Trust (File No. 811-22148) (the “ETF Registrant”) (each, an “ETF Registrant” and collectively, the “ETF Registrants” and together, with the OEF Registrants, the “Registrants”)

Dear Mr. Manion:

On behalf of the Registrants and each respective series of the Registrants listed in Exhibit A (each, a “Fund,” and collectively, the “Funds”) this letter responds to comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities Exchange Commission (the “Commission” or “SEC”) to the undersigned on June 3, 2021, with respect to the Registrants’ respective shareholder reports filed on Form N-CSR and the annual reports on Form N-CEN for the fiscal years ended on the dates listed in Exhibit A.

The Staff’s comments are summarized below in italicized text. The Registrants’ responses are set out immediately under the restated comment.

I.
FINANCIAL STATEMENT AND N-CSR COMMENTS
     
1.
Comment:
The annual report for each of the Funds listed on Exhibit B states that the Fund is non-diversified.  Please confirm such Funds continue to qualify as non-diversified funds, and also please identify the compliance testing performed to monitor each Fund’s diversification status.  The Staff reminds the Registrants that if any such Fund has been operating as diversified for more than three years, the Fund would be required to obtain shareholder approval prior to changing its operating status back to non-diversified.
     
 
Response:
For each of the Funds listed on Exhibit B, a Fund may, from time to time, operate as diversified based on the composition of such Fund’s underlying index.  The compliance department of the ETF Registrants’ adviser monitors the diversification status of each Fund on a daily basis.  Certain of these Funds have operated as diversified for a continuous three-year period, and as a result (and


   
subsequent to the date of the Fund’s annual report), the classification status of such Funds has been changed to diversified. That change has been disclosed to shareholders via a supplement to the Fund’s registration statement.  The current diversification status of each Fund is listed on Exhibit B.  For each Fund that has operated in a diversified manner continuously for a three-year period, we confirm that the Fund would seek shareholder approval prior to changing its operating status back to non-diversified, unless the Fund could rely on the no-action letter issued to Stradley Ronon Stevens & Young, LLP on June 24, 2019.  We also confirm that the Funds listed as non-diversified on Exhibit B continue to qualify as non-diversified.
     
2.
Comment:
In the October 31, 2020 annual report for Invesco Emerging Markets Local Debt Fund, certain column headers of the Financial Highlights table appear to have been transposed as certain figures in the Financial Highlights table do not align with prior years.  Please assess whether an amendment to the N-CSR is necessary and explain in correspondence your analysis regarding your proposed approach.
     
 
Response:
The Registrant confirms that certain column headers (specifically, the net expense ratio and net investment income ratio headers) of the Financial Highlights table are transposed.  The Registrant undertook an assessment to determine whether an amendment to the N-CSR is necessary and believes that such amendment is not necessary.  In arriving at that conclusion, the Registrant considered both quantitative and qualitative factors, including that (i) all fiscal year 2020 ratios were correctly reported in the October 31, 2020 annual report and it was only prior fiscal year end ratios impacted by the transposition; (ii) the transposition resulted in the Fund’s net expense ratios and net investment income ratios for certain prior fiscal years appearing worse than they actually were (not better); (iii) all shareholder reports for Invesco Emerging Markets Local Debt Fund issued prior to the October 31, 2020 annual report accurately presented all figures in the Financial Highlights; (iv) the semi-annual report dated April 30, 2021 accurately presents all figures in the Financial Highlights; (v) the transposed numbers, covering the period between May 31, 2016 to October 31, 2019, are approaching two years old; and (vi) the prospectus, which currently reflects the transposed information, will be amended to reflect the correct presentation.  Based on all of the foregoing, the Registrant concluded the information is not material and amending the N-CSR would incur additional expense without providing any real additional value.
     
3.
Comment:
Per the October 31, 2020 annual report for the Invesco S&P 500 Downside Hedged ETF, the Fund held primarily money market funds plus other assets at fiscal year end. Please explain whether this was in connection with a rebalancing or due to defensive positioning. If due to defensive positioning, consider adding disclosure regarding the Fund’s defensive strategy to the Fund’s summary prospectus.
     
 
Response:
The ETF Registrant confirms that the Fund’s holding of primarily money market funds plus other assets at the fiscal year end was due to the application of the Fund’s investment strategy, as the Fund sought to reposition its portfolio away from equity holdings during a period of greater volatility, in accordance with the rebalancing of the S&P 500® Dynamic VEQTOR Index.  The Fund respectfully notes that the Management’s Discussion of Fund Performance in the annual report states the following regarding such positioning:
 
Consistent with its investment strategy, the Fund moves to a substantial cash position from time to time during periods of heightened volatility.  In this
2


   
regard, at the Fund’s fiscal year ended October 31, 2020, the Fund held primarily money market funds plus other assets.
 
The ETF Registrant further notes that the Fund’s summary prospectus discloses that the Fund will invest in short-term, high quality U.S. Treasury Securities, money market instruments, cash, and cash equivalent securities “to protect the Fund during periods of heightened volatility when the Adviser believes that it is in the best interest of the Fund to do so.”  Although the allocation to primarily money market funds was not done as a defensive positioning strategy, the ETF Registrant also notes that its statutory prospectus (which is incorporated by reference into the summary prospectus) discloses that the Fund may take such temporary defensive positions under the bolded heading “Temporary Defensive Strategies.”
     
4.
Comment:
For the fiscal year ended November 30, 2020 of the Invesco SteelPath MLP Alpha Fund, Invesco SteelPath MLP Alpha Plus Fund, Invesco SteelPath MLP Income Fund and Invesco SteelPath MLP Select 40 Fund, please confirm that the recapture positions of Section 751 of the Internal Revenue Code (“IRC”) were considered in connection with the determination of the Funds’ NAV.
 
 
Response:
The Registrant confirms that IRC 751 recapture provisions were considered in connection with the determination of the Funds’ NAV.
     
5.
Comment:
Please confirm that the Funds have complied with Section 19(a) of the Investment Company Act of 1940, as amended, as applicable.
     
 
Response:
The Registrants confirm their belief that the Funds have complied with Section 19(a) of the Investment Company Act of 1940, as amended, as applicable, based on and consistent with the adviser’s internal procedures concerning compliance with Section 19(a), which procedures it believes are appropriate and reasonable.
     
II.
FORM N-CEN COMMENT
     
6.
Comment:
For the Invesco BulletShares 2023 Municipal Bond ETF, please reconcile the response to Item C.8.c. (Are the fees waived subject to recoupment?) which was checked “no,” with the response to Item C.8.d. (Were any expenses previously waived recouped during the period?) which was checked “yes.”  Please confirm whether fees waived are subject to recoupment and whether any such fees were recouped.
     
 
Response:
The ETF Registrant confirms that fees waived for Invesco BulletShares 2023 Municipal Bond ETF are not subject to recoupment and also that the Fund did not recoup any previously waived expenses during the period. The ETF Registrant notes that the response to Item C.8.c. is correct, and that the response to Item C.8.d. should be “no” and that the incorrect box for that item was inadvertently checked.

Please do not hesitate to contact me at (713) 214-4345 if you have any questions or wish to discuss any of the responses presented above.

Sincerely,


/s/Adrien Deberghes
Adrien Deberghes
Principal Financial Officer, Treasurer and Vice President of the OEF Registrants
3


Vice President of the ETF Registrants

cc:
Kelli Gallegos
Sheri Morris
Taylor Edwards
Mark Greer
Mena Larmour

4


EXHIBIT A

File #
Registrant Name
Series ID
Series Name
FYE Reviewed
811-05686
AIM INVESTMENT SECURITIES FUNDS (INVESCO INVESTMENT SECURITIES FUNDS)
S000064666
Invesco High Yield Bond Factor Fund
2/29/2020
811-05686
AIM INVESTMENT SECURITIES FUNDS (INVESCO INVESTMENT SECURITIES FUNDS)
S000064669
Invesco U.S. Government Money Portfolio
2/29/2020
811-07890
AIM TAX-EXEMPT FUNDS (INVESCO TAX-EXEMPT FUNDS)
S000064643
Invesco Rochester AMT-Free New York Municipal Fund
2/29/2020
811-03826
AIM SECTOR FUNDS (INVESCO SECTOR FUNDS)
S000064611
Invesco Gold & Special Minerals Fund
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000063395
Invesco S&P 500(R) Equal Weight Communication Services ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060788
Invesco S&P 500(R) Equal Weight Real Estate ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060798
Invesco S&P 500 Equal Weight Consumer Discretionary ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060811
Invesco S&P 500 Equal Weight Energy ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060812
Invesco S&P 500 Equal Weight ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060813
Invesco S&P 500 Equal Weight Financials ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060814
Invesco S&P 500 Equal Weight Health Care ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060815
Invesco S&P 500 Equal Weight Industrials ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060816
Invesco S&P 500 Equal Weight Materials ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060789
Invesco S&P 500 Equal Weight Technology ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060790
Invesco S&P 500 Equal Weight Utilities ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060791
Invesco S&P 500 Pure Growth ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060792
Invesco S&P 500 Pure Value ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060793
Invesco S&P 500 Top 50 ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060794
Invesco S&P MidCap 400 Equal Weight ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060795
Invesco S&P MidCap 400 Pure Growth ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060796
Invesco S&P MidCap 400 Pure Value ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060797
Invesco S&P SmallCap 600 Equal Weight ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060799
Invesco S&P SmallCap 600 Pure Growth ETF
4/30/2020
5


File #
Registrant Name
Series ID
Series Name
FYE Reviewed
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060800
Invesco S&P SmallCap 600 Pure Value ETF
4/30/2020
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
S000060809
Invesco S&P 500 Equal Weight Consumer Staples ETF
8/31/2020
811-21977
Invesco Exchange-Traded Fund Trust II
S000058746
Invesco PureBeta MSCI USA ETF
8/31/2020
811-21977
Invesco Exchange-Traded Fund Trust II
S000058747
Invesco PureBeta MSCI USA Small Cap ETF
8/31/2020
811-21977
Invesco Exchange-Traded Fund Trust II
S000058750
Invesco PureBeta US Aggregate Bond ETF
8/31/2020
811-21977
Invesco Exchange-Traded Fund Trust II
S000060822
Invesco Solar ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060849
Invesco BulletShares 2020 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060850
Invesco BulletShares 2020 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060851
Invesco BulletShares 2021 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060832
Invesco BulletShares 2021 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062843
Invesco BulletShares 2021 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062836
Invesco BulletShares 2021 USD Emerging Markets Debt ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060833
Invesco BulletShares 2022 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060834
Invesco BulletShares 2022 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062844
Invesco BulletShares 2022 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062837
Invesco BulletShares 2022 USD Emerging Markets Debt ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060835
Invesco BulletShares 2023 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060836
Invesco BulletShares 2023 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062845
Invesco BulletShares 2023 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062838
Invesco BulletShares 2023 USD Emerging Markets Debt ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060837
Invesco BulletShares 2024 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060838
Invesco BulletShares 2024 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062846
Invesco BulletShares 2024 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062839
Invesco BulletShares 2024 USD Emerging Markets Debt ETF
8/31/2020
6


File #
Registrant Name
Series ID
Series Name
FYE Reviewed
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060839
Invesco BulletShares 2025 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060842
Invesco BulletShares 2025 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062847
Invesco BulletShares 2025 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060840
Invesco BulletShares 2026 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062552
Invesco BulletShares 2026 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062848
Invesco BulletShares 2026 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060831
Invesco BulletShares 2027 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000066017
Invesco BulletShares 2027 High Yield Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062849
Invesco BulletShares 2027 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062551
Invesco BulletShares 2028 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062841
Invesco BulletShares 2028 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000066016
Invesco BulletShares 2029 Corporate Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000066147
Invesco BulletShares 2029 Municipal Bond ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000060841
Invesco Defensive Equity ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062197
Invesco Investment Grade Defensive ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062198
Invesco Investment Grade Value ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062833
Invesco RAFI(TM) Strategic Developed ex-US ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062835
Invesco RAFI(TM) Strategic Emerging Markets ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062831
Invesco RAFI(TM) Strategic US ETF
8/31/2020
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
S000062832
Invesco RAFI(TM) Strategic US Small Company ETF
8/31/2020
811-01424
AIM EQUITY FUNDS (INVESCO EQUITY FUNDS)
S000064631
Invesco Main Street All Cap Fund
10/31/2020
811-05426
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
S000064693
Invesco Emerging Markets Local Debt Fund
10/31/2020
811-06463
AIM INTERNATIONAL MUTUAL FUNDS (INVESCO INTERNATIONAL MUTUAL FUNDS)
S000064622
Invesco Global Focus Fund
10/31/2020
811-21977
Invesco Exchange-Traded Fund Trust II
S000058751
Invesco PureBeta 0-5 Yr US TIPS ETF
10/31/2020
7


File #
Registrant Name
Series ID
Series Name
FYE Reviewed
811-21977
Invesco Exchange-Traded Fund Trust II
S000058748
Invesco PureBeta FTSE Developed ex-North America ETF
10/31/2020
811-21977
Invesco Exchange-Traded Fund Trust II
S000058749
Invesco PureBeta FTSE Emerging Markets ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000023365
Invesco Active U.S. Real Estate ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000056349
Invesco Balanced Multi-Asset Allocation ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000056347
Invesco Conservative Multi-Asset Allocation ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000056350
Invesco Growth Multi-Asset Allocation ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000056348
Invesco Moderately Conservative Multi-Asset Allocation ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000036643
Invesco S&P 500 Downside Hedged ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000060784
Invesco Total Return Bond ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000060783
Invesco Ultra Short Duration ETF
10/31/2020
811-22148
INVESCO ACTIVELY MANAGED EXCHANGE-TRADED FUND TRUST
S000051678
Invesco Variable Rate Investment Grade ETF
10/31/2020
811-05426
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
S000064699
Invesco SteelPath MLP Alpha Fund
11/30/2020
811-05426
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
S000064701
Invesco SteelPath MLP Alpha Plus Fund
11/30/2020
811-05426
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
S000064700
Invesco SteelPath MLP Income Fund
11/30/2020
811-05426
AIM INVESTMENT FUNDS (INVESCO INVESTMENT FUNDS)
S000064698
Invesco SteelPath MLP Select 40 Fund
11/30/2020
811-02699
AIM GROWTH SERIES (INVESCO GROWTH SERIES)
S000064649
Invesco International Diversified Fund
12/31/2020
811-02699
AIM GROWTH SERIES (INVESCO GROWTH SERIES)
S000064651
Invesco Main Street Mid Cap Fund
12/31/2020
811-02699
AIM GROWTH SERIES (INVESCO GROWTH SERIES)
S000064650
Invesco Main Street Small Cap Fund
12/31/2020


8


EXHIBIT B

File #
Registrant Name
Series Name
Diversification Status
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Consumer Discretionary ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Consumer Staples ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Energy ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Financials ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Health Care ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Industrials ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Materials ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Real Estate ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Technology ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Equal Weight Utilities ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Pure Growth ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Pure Value ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P 500® Top 50 ETF
Non-diversified
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P MidCap 400® Equal Weight ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P MidCap 400® Pure Growth ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P MidCap 400® Pure Value ETF
Diversified
(per April 23, 2021 supplement)
9


File #
Registrant Name
Series Name
Diversification Status
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P SmallCap 600® Equal Weight ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P SmallCap 600® Pure Growth ETF
Diversified
(per April 23, 2021 supplement)
811-21265
INVESCO EXCHANGE-TRADED FUND TRUST
Invesco S&P SmallCap 600® Pure Value ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2021 Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2021 High Yield Corporate Bond ETF
Non-diversified
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2022 Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2022 High Yield Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2023 Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2023 High Yield Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2024 Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2024 High Yield Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2025 Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco BulletShares 2026 Corporate Bond ETF
Diversified
(per April 23, 2021 supplement)
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco Investment Grade Defensive ETF
Non-diversified
811-23304
Invesco Exchange-Traded Self-Indexed Fund Trust
Invesco Investment Grade Value ETF
Non-diversified

10