0001145549-23-027593.txt : 20230515 0001145549-23-027593.hdr.sgml : 20230515 20230515163125 ACCESSION NUMBER: 0001145549-23-027593 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 4 CONFORMED PERIOD OF REPORT: 20230228 FILED AS OF DATE: 20230515 DATE AS OF CHANGE: 20230515 EFFECTIVENESS DATE: 20230515 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: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-22668 FILM NUMBER: 23923184 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 0001540305 S000061208 U.S. Diversified Real Estate ETF C000198249 U.S. Diversified Real Estate ETF PPTY 0001540305 S000065033 NetLease Corporate Real Estate ETF C000210573 NETLease Corporate Real Estate ETF NETL 0001540305 S000065066 Hoya Capital Housing ETF C000210709 Hoya Capital Housing ETF HOMZ 0001540305 S000073033 Hoya Capital High Dividend Yield ETF C000229810 Hoya Capital High Dividend Yield ETF RIET N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001540305 XXXXXXXX false false false N-1A S000065066 true S000073033 true S000061208 true S000065033 true ETF Series Solutions 811-22668 0001540305 5493008BB0X0GYS3UI50 c/o U.S. Bancorp Fund Services LLC 615 East Michigan Street Milwaukee 53202 US-WI US 4145161645 U.S. Bancorp Fund Services LLC 615 East Michigan Street Milwaukee 53202 8336121912 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 U.S. Bank National Association 1555 N. Rivercenter Drive Suite 302 Milwaukee 53212 8336121912 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 Quasar Distributors, LLC 111 E Kilbourn Ave Suite 2200 Milwaukee 53202 8883629248 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 Act for certain Series within the Registrant. ClearShares LLC 606 Bald Eagle Drive Suite 608 Marco Island 34145 2122920959 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for OCIO, OPER and PIFI only. Vident Investment Advisory, LLC 1125 Sanctuary Parkway Suite 515 Alpharetta 30009 4044871961 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 Act for certain Series within the Registrant. Vident Advisory, LLC 1125 Sanctuary Parkway Suite 515 Alpharetta 30009 4045274220 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for PPTY, VIDI, VUSE and VBND only. Little Harbor Advisors, LLC 30 Doaks Lane Marblehead 01945 7816393000 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for MSVX, MSTB, and MSTQ only. Exchange Traded Concepts, LLC 10900 Hefner Pointe Drive Suite 400 Oklahoma City 73120 4057788377 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 Act for BNE, DEEP, CNCR, RITA, KARB, CHNA, PSYK, DIP, and NETL only. AlphaMark Advisors, LLC 810 Wright's Summit Pkwy Suite 100 Fort Wright 41011 8599571803 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for SMCP only. Penserra Capital Management LLC 4 Orinda Way Suite 100-A Orinda 94563 8004568850 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 Act for certain Series within the Registrant. Nationwide Fund Advisors One Nationwide Plaza Columbus 43215 8776696877 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for NUSI, NDJI, NTKI, and NSPI only. Defiance ETFs, LLC 78 SW 7th Street 9th Floor Miami 33130 8333339383 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for FIVG, QTUM, HDRO, IBIT, and CRUZ only. Toroso Investments, LLC 898 N Broadway St. Suite 2 Massapequa 11758 8449867676 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for ZIG only. Advisors Asset Management, Inc. 18925 Base Camp Road Suite 203 Monument 80132 7194889956 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for SPDV, EEMD, DMDV, PFLD, TRFM and SMIG only. U.S. Global Investors, Inc. 7900 Callaghan Road San Antonio 78229 2103081294 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for JETS, GOAU and SEA only. Acquirers Funds, LLC 609 Deep Valley Drive Suite 200 Rolling Hills 90274 6465358629 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for ZIG only. Point Bridge Capital, LLC 300 Throckmorton Street Suite 1550 Fort Worth 76102 8175294600 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for MAGA only. Foreside Fund Services, LLC Three Canal Plaza Portland 04101 8662516920 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 Act for certain Series within the Registrant. Aptus Capital Advisors, LLC 265 Young Street Fairhope 36532 2515177198 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for OSCV, ADME, DRSK, IDME, MSMR, JUCY, and ACIO only. Distillate Capital Partners LLC 53 West Jackson Blvd Suite 530 Chicago 60604 8006170004 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for DSTL, DSTX, and DSMC only. Hoya Capital Real Estate LLC 137 Rowayton Avenue Suite 430 Rowayton 06853 8334692227 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for HOMZ and RIET only. Beyond Investing LLC 14391 Spring Hill Drive Suite 301 Spring Hill 34609 8443299300 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for VEGN only. Harvest Volatility Management, LLC 420 Lexington Avenue Suite 2620 New York 10170 2126827822 The books and records required to be maintained by Section 31a of the Investment Company Act of 1940 for NUSI, NDJI, NTKI, and NSPI only. ALPS Distributors, Inc 1290 Broadway Suite 1000 Denver 80203 3036232577 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for PPTY, VIDI, VUSE and VBND only. Bahl & Gaynor, Inc. 255 East Fifth Street Cincinnati 45202 5132876100 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for SMIG only. McElhenny Sheffield Capital Management LLC 4701 W. Lovers Lane Dallas 75209 2149229200 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for MSMR only. Inherent Wealth Fund LLC Four Embarcadero Center, Suite 1400 San Francisco 94111 19339102700 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for IBET only. Blueprint Investment Partners LLC 1250 Revolution Mill Drive Suite 150 Greensboro 27405 8002457339 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for OCIO only. Piton Investment Management, L.P. 401 Franklin Avenue Suite 202B Garden City 11530 6465182800 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for OPER and PIFI only. Grayscale Advisors, LLC 290 Harbor Drive 4th Floor Stamford 06902 2126681427 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for GFOF only. Kaiju ETF Advisors 33 N. LaSalle Street Suite 2210 Chicago 60602 3125780690 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for DIP only. Cboe Vest Financial LLC 8350 Broad Street Suite 240 McLean 22102 8559796060 The books and records required to be maintained by Section 31(a) of the Investment Company Act of 1940 for RYSE only. N N N N-1A 56 Y Michael A. Castino 004710889 Y Janet D. Olsen 004312346 N David A. Massart 002332208 N Leonard M. Rush 000726159 N Cynthia Andrae N/A c/o U.S. Bancorp Fund Services LLC 615 E. Michigan Street Milwaukee 53202 XXXXXX N N N N N Quasar Distributors, LLC 8-52323 000103848 N/A N Foreside Funds Distributors LLC 8-32480 000031334 N/A N ALPS Distributors, Inc 8-34626 000016853 N/A N N Cohen & Company, Ltd. 00925 N/A N N N N N Hoya Capital Housing ETF S000065066 5493006GQFVD88T27V21 N 1 0 0 Exchange-Traded Fund Y Y -0.024068727007 -0.297957617007 0.122984397333 0.123200487972 N N Y N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Rule 32a-4 (17 CFR 270.32a-4) Rule 6c-11 (17 CFR 270.6c-11) N N N N Hoya Capital Real Estate, LLC 801-114767 000281848 N/A N Penserra Capital Management LLC 801-80466 000159042 549300I8X5UWMSXOJ371 N N U.S. Bancorp Fund Services, LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N ICE Data Pricing & Reference Data, LLC 5493000NQ9LYLDBCTL34 N N U.S. Bank National Association 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N N U.S. Bancorp Fund Services, LLC N1GZ7BBF3NP8GI976H15 N N N Penserra Securities LLC 008-67773 000145994 549300WY8ZBI168Y6Z05 0.000000000000 JANE STREET EXECUTION SERVICES, LLC 008-69254 000167280 549300HXJLXCPDWAH070 2868.000000000000 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED 008-07221 000007691 8NAV47T0Y26Q87Y0QP81 2561.000000000000 5429.000000000000 0.000000000000 N 41352233.815000000000 N N N Hoya Capital High Dividend Yield ETF S000073033 549300J6T1FHX4RHKS53 N 1 0 0 Exchange-Traded Fund Y Y 0.039806165321 -0.392709554679 0.322583910352 0.322834997805 N N Y N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Rule 32a-4 (17 CFR 270.32a-4) Rule 6c-11 (17 CFR 270.6c-11) Y Y N N Hoya Capital Real Estate, LLC 801-114767 000281848 N/A N Penserra Capital Management LLC 801-80466 000159042 549300I8X5UWMSXOJ371 N N U.S. Bancorp Fund Services, LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N ICE Data Pricing & Reference Data, LLC 5493000NQ9LYLDBCTL34 N N U.S. Bank National Association 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N N U.S. Bancorp Fund Services, LLC N1GZ7BBF3NP8GI976H15 N N N Penserra Securities LLC 008-67773 000145994 549300WY8ZBI168Y6Z05 0.000000000000 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED 008-07221 000007691 8NAV47T0Y26Q87Y0QP81 7279.000000000000 JANE STREET EXECUTION SERVICES, LLC 008-69254 000167280 549300HXJLXCPDWAH070 4435.000000000000 11714.000000000000 0.000000000000 N 25143971.700000000000 N N N U.S. Diversified Real Estate ETF S000061208 549300RLPYZATE397T12 N 1 0 0 Exchange-Traded Fund Y N -0.006891890243 -0.424058570243 0.107498062314 0.107738631316 N N Y N N U.S. Bank, N.A. 6BYL5QZYBDK8S7L73M02 N N Revenue sharing split Cash collateral reinvestment fee 33497729.400000000000 48011.560000000000 Rule 12d1-1 (17 CFR 270.12d1-1) Rule 32a-4 (17 CFR 270.32a-4) Rule 6c-11 (17 CFR 270.6c-11) Y Y N N Vident Asset Management 801-114538 000286622 N/A N Vident Investment Advisory, LLC 801-80534 000171004 254900XSZB691Z1A6X78 Y N U.S. Bancorp Fund Services, LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N ICE Data Pricing & Reference Data, LLC 5493000NQ9LYLDBCTL34 N N U.S. Bank National Association 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N N U.S. Bancorp Fund Services LLC N1GZ7BBF3NP8GI976H15 N N N MISCHLER FINANCIAL GROUP, INC. 008-48067 000037818 2549004IPXPSM9EJFC92 43019.000000000000 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED 008-07221 000007691 8NAV47T0Y26Q87Y0QP81 667.000000000000 BTIG, LLC 008-65473 000122225 549300GTG9PL6WO3EC51 293.000000000000 TELSEY ADVISORY GROUP LLC 008-67988 000148234 54930080BFVVEZCZGF48 293.000000000000 WALLACHBETH CAPITAL LLC 008-67936 000147853 549300R371KUKXEXC133 75.000000000000 GOLDMAN SACHS & CO. LLC 008-00129 000000361 FOR8UP27PHTHYVLBNG30 13.000000000000 44360.000000000000 0.000000000000 N 128914288.000000000000 N N N NETLease Corporate Real Estate ETF S000065033 549300BF1J91U6ZBHF60 N 1 0 0 Exchange-Traded Fund N Y -0.019151000000 -0.593165000000 0.127674000000 0.127982000000 Y N Y N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Rule 32a-4 (17 CFR 270.32a-4) Rule 6c-11 (17 CFR 270.6c-11) N N N N Exchange Traded Concepts, LLC 801-70485 000151197 549300BB5DRIKK8VVV91 N U.S. Bancorp Fund Services, LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N ICE Data Pricing & Reference Data, LLC 5493000NQ9LYLDBCTL34 N N U.S. Bank National Association 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N N U.S. Bancorp Fund Services, LLC N1GZ7BBF3NP8GI976H15 N N N BTIG LLC 008-65473 000122225 549300GTG9PL6WO3EC51 138.000000000000 MERRILL LYNCH PIERCE FENNER & SMITH INCORPORATED 008-07221 000007691 8NAV47T0Y26Q87Y0QP81 24366.000000000000 24504.000000000000 0.000000000000 N 106564915.650000000000 N N N Hoya Capital Housing ETF S000065066 N 25000.000000000000 100.000000000000 0.000000000000 0.000000000000 0.000000000000 1.390726315789 0.338970926935 98.609173684211 0.338970926935 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 Y Hoya Capital High Dividend Yield ETF S000073033 N 10000.000000000000 3.729855000000 11.353098300000 96.270047000000 11.353086690000 1.416433000000 1.107021630000 98.583500000000 1.107067679000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 Y U.S. Diversified Real Estate ETF S000061208 N 50000.000000000000 0.183200000000 0.800481640014 99.816740000000 0.800522286011 -0.248520000000 0.492251087962 100.248480000000 0.492291984091 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 N NETLease Corporate Real Estate ETF S000065033 N 25000.000000000000 0.591537000000 0.213115116000 99.408363000000 0.213115116000 1.446239000000 2.611687035000 98.553661000000 2.611687035000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 0.000000000000 300.000000000000 0.000000000000 Y true INTERNAL CONTROL RPT 2 netl_internalcontrolrpt.htm NETL INTERNAL CONTROL REPORT

  

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 

  

To the Shareholders of NETLease Corporate Real Estate ETF and  

Board of Trustees of ETF Series Solutions 

  

In planning and performing our audit of the financial statements of NETLease Corporate Real Estate ETF (“the Fund”), a series of ETF Series Solutions, as of and for the year ended February 28, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund’s internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting.  Accordingly, we express no such opinion. 

  

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP).  A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.  

  

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. 

  

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund’s annual or interim financial statements will not be prevented or detected on a timely basis. 

  

Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB.  However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of February 28, 2023.  

  

This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties. 

  

/s/ COHEN & COMPANY, LTD. 

  

COHEN & COMPANY, LTD. 

Milwaukee, Wisconsin 

April 27, 2023 

  

INTERNAL CONTROL RPT 3 ppty_internalcontrolrpt.htm PPTY INTERNAL CONTROL REPORT

  

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 

  

To the Shareholders of U.S. Diversified Real Estate ETF and  

Board of Trustees of ETF Series Solutions 

  

In planning and performing our audit of the financial statements of U.S. Diversified Real Estate ETF (the “Fund”), a series of ETF Series Solutions, as of and for the year ended February 28, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund’s internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting.  Accordingly, we express no such opinion. 

  

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP).  A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.  

  

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. 

  

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund’s annual or interim financial statements will not be prevented or detected on a timely basis. 

  

Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB.  However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of February 28, 2023.  

  

This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties. 

  

/s/ COHEN & COMPANY, LTD. 

  

COHEN & COMPANY, LTD. 

Milwaukee, Wisconsin 

April 27, 2023 

  

INTERNAL CONTROL RPT 4 hoyaetfs_internalcontrolrpt.htm HOYA ETFS INTERNAL CONTROL REPORT

  

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 

  

To the Shareholders of Hoya Capital ETFs and  

Board of Trustees of ETF Series Solutions 

  

In planning and performing our audit of the financial statements of Hoya Capital Housing ETF and Hoya Capital High Dividend Yield ETF (the “Funds”), each a series of ETF Series Solutions, as of and for the year ended February 28, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Funds’ internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds’ internal control over financial reporting.  Accordingly, we express no such opinion. 

  

The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP).  A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.  

  

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. 

  

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Funds’ annual or interim financial statements will not be prevented or detected on a timely basis. 

  

Our consideration of the Funds’ internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB.  However, we noted no deficiencies in the Funds’ internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of February 28, 2023.  

  

This report is intended solely for the information and use of management and the Board of Trustees of the Funds and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties. 

  

/s/ COHEN & COMPANY, LTD. 

  

COHEN & COMPANY, LTD. 

Milwaukee, Wisconsin 

April 27, 2023