COVER 4 filename4.htm

July 20, 2017

 

VIA EDGAR  
   

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-1090

 

 

Re: Oppenheimer Revenue Weighted ETF Trust
Post-Effective Amendment No. 43 under the Securities Act
and Amendment No. 45 under the Investment Company Act
File Nos. 333-139501; 811-21993

 

 

To the Securities and Exchange Commission:

 

An electronic (EDGAR) filing is transmitted herewith pursuant to the Securities Act of 1933, as amended (the “Securities Act”), and the Investment Company Act of 1940, as amended (the “Investment Company Act”), on behalf of Oppenheimer Revenue Weighted ETF Trust (the “Registrant”). This filing constitutes Post-Effective Amendment No. 43 under the Securities Act and Amendment No. 45 under the Investment Company Act (the “Amendment”) to the Registrant’s Registration Statement on Form N-1A (the “Registration Statement”).

 

This filing is being made pursuant to Rule 485(a) under the Securities Act to register shares of Oppenheimer Russell 1000 Low Volatility Factor ETF, Oppenheimer Russell 1000 Momentum Factor ETF, Oppenheimer Russell 1000 Quality Factor ETF, Oppenheimer Russell 1000 Size Factor ETF, Oppenheimer Russell 1000 Value Factor ETF and Oppenheimer Russell 1000 Yield Factor ETF, each a proposed new series of the Trust (the “New Funds”). Pursuant to SEC Release No. IC-13768 (February 14, 1984) under the Investment Company Act, the Registrant respectfully requests selective review of the Amendment to limit review to the following sections of the Prospectus and Statement of Additional Information (“SAI”):

 

Prospectus

 

·The sections titled "FUND SUMMARIES," "INVESTMENT OBJECTIVE, PRINCIPAL INVESTMENT STRATEGIES, RELATED RISKS, AND DISCLOSURE OF PORTFOLIO HOLDINGS," and “MANAGEMENT OF THE FUNDS.”
SAI

 

·The sections titled "INVESTMENT STRATEGIES," "INVESTMENT RESTRICTIONS," “MANAGEMENT OF THE TRUST,” and “INVESTMENT ADVISORY, PRINCIPAL UNDERWRITING AND OTHER SERVICE ARRANGEMENTS.”

 

The Registrant believes that selective review of the above sections is proper because the remaining sections of the prospectus and SAI are substantially similar and not materially different from those same sections most recently reviewed by SEC staff in Post-Effective Amendment No. 38 under the Securities Act and Amendment No. 40 under the Investment Company Act, filed December 22, 2016 (SEC Accession No. 0000728889-16-004352).

 

This filing is scheduled to go effective in seventy-five days on October 3, 2017, as indicated on the facing page. We anticipate that an amendment to the Registration Statement will be filed on or about October 3, 2017, including (i) responses to any comments of the Securities and Exchange Commission Staff on this filing; (ii) updated expense information; and (iii) other, non-material changes.

 

The Securities and Exchange Commission Staff is requested to address any comments or questions you may have on this filing to:

 

Taylor Edwards, Esq.
Senior Vice President & Managing Counsel
OFI Global Asset Management, Inc.
225 Liberty Street
New York, New York 10281-1008
212-323-0310
tedwards@ofiglobal.com

 

 

  Sincerely,
 

/s/ Carolyn Liu-Hartman

 

  Carolyn Liu-Hartman
Vice President & Associate General Counsel

 

cc:

Ropes & Gray LLP
Emily Ast Esq.

Taylor Edwards Esq.

Gloria LaFond