0000894189-21-003947.txt : 20210923 0000894189-21-003947.hdr.sgml : 20210923 20210624115627 ACCESSION NUMBER: 0000894189-21-003947 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210624 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ETF Series Solutions CENTRAL INDEX KEY: 0001540305 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1112 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 615 EAST MICHIGAN ST CITY: MILWAUKEE STATE: WI ZIP: 53202 BUSINESS PHONE: 414-287-3700 MAIL ADDRESS: STREET 1: 615 EAST MICHIGAN ST CITY: MILWAUKEE STATE: WI ZIP: 53202 CORRESP 1 filename1.htm Document

ETF Series Solutions
615 East Michigan Street | Milwaukee, Wisconsin 53202
June 25, 2021
Mr. David Orlic
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street NE
Washington, DC 20549
Re:ETF Series Solutions (the “Trust”)
AAM Bahl & Gaynor Small/Mid Cap Income Growth ETF (the “Fund”)
File Nos. 333-179562 and 811-22668
Dear Mr. Orlic:
This correspondence responds to additional comments that the Trust received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission with respect to Post-Effective Amendment No. 698 to the Trust’s Registration Statement on Form N-1A filed May 7, 2021 (the “Amendment”) with respect to the Fund, a series of the Trust. For your convenience, the comments have been reproduced with a response following each comment. Capitalized terms not otherwise defined have the same meaning as in the Amendment.
Comment 1.Please order the risks to prioritize those risks that are most likely to adversely affect the Fund’s net asset value, yield, and/or total return. Please note that after listing the most significant risks to the Fund, the remaining risks may be alphabetized. Please refer to ADI 2019-08 “Improving Principal Risks Disclosure.”
Response:     The Trust has reviewed the Fund’s risk disclosures to ensure that such disclosures are tailored appropriately to the risks of the Fund, not overly lengthy or technical, and that the risks the Staff would consider as the most significant risks are not obscured or constructed in a manner that could render the disclosure misleading. Additionally, the Trust believes that ordering the risks alphabetically makes it easier for investors to find applicable risk factors and compare them across funds.
While the Trust respectfully declines to reorder the principal risks, the Trust notes that the following disclosure is included before the first paragraph under “Principal Investment Risks” in the Fund’s summary section with similar language in response to Item 9 of Form N-1A to help investors understand the importance of reading each risk disclosure regardless of their sequence: “The principal risks are presented in alphabetical order to facilitate finding particular risks and comparing them with other funds. Each risk summarized below is considered a ‘principal risk’ of investing in the Fund, regardless of the order in which it appears.”
Comment 2.With respect to the “ETF Risks—Trading” risk disclosure, please note that the adverse effect of stressed market conditions on the liquidity for the Fund’s shares, in turn, could also lead to differences in the market price of the Fund’s shares and the underlying value of those shares.
Response:     The last sentence of the above-referenced risk has been revised to read as follows:
In stressed market conditions, the liquidity of Shares may begin to mirror the liquidity of the Fund’s underlying portfolio holdings, which can be significantly less liquid than Shares, and this could lead to differences between the market price of the Shares and the underlying value of those Shares.
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If you have any questions regarding the above response, please contact Alyssa Bernard at (920) 360‑7173 or alyssa.bernard@usbank.com.

Sincerely,


/s/ Michael D. Barolsky
Michael D. Barolsky
Vice President and Secretary