0000940400-23-000316.txt : 20230828 0000940400-23-000316.hdr.sgml : 20230828 20230828102519 ACCESSION NUMBER: 0000940400-23-000316 CONFORMED SUBMISSION TYPE: N-CSR PUBLIC DOCUMENT COUNT: 5 CONFORMED PERIOD OF REPORT: 20230630 FILED AS OF DATE: 20230828 DATE AS OF CHANGE: 20230828 EFFECTIVENESS DATE: 20230828 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BNY Mellon ETF Trust CENTRAL INDEX KEY: 0001493580 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FILING VALUES: FORM TYPE: N-CSR SEC ACT: 1940 Act SEC FILE NUMBER: 811-23477 FILM NUMBER: 231211562 BUSINESS ADDRESS: STREET 1: 240 GREENWICH STREET CITY: NEW YORK STATE: NY ZIP: 10286 BUSINESS PHONE: 212-922-6400 MAIL ADDRESS: STREET 1: 240 GREENWICH STREET CITY: NEW YORK STATE: NY ZIP: 10286 FORMER COMPANY: FORMER CONFORMED NAME: Dreyfus ETF Trust DATE OF NAME CHANGE: 20100607 0001493580 S000072501 BNY Mellon Ultra Short Income ETF C000228810 BNY Mellon Ultra Short Income ETF BKUI 0001493580 S000072693 BNY Mellon Responsible Horizons Corporate Bond ETF C000229128 BNY Mellon Responsible Horizons Corporate Bond ETF RHCB N-CSR 1 primary-document.htm
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number            811-23477                  
                          BNY Mellon ETF Trust                               

(Exact name of registrant as specified in charter)
240 Greenwich Street
_____________New York, New York 10286_____________

(Address of principal executive offices) (Zip code)
 
Deirdre Cunnane, Esq.
240 Greenwich Street
_________________New York, New York 10286_____________
(Name and address of agent for service)
 
Registrant's telephone number, including area code: (212) 922-6400
Date of fiscal year end:  June 30
Date of reporting period:  June 30, 2023
 
The following N-CSR relates only to the Registrant's series listed below and does not relate to any series of the Registrant with a different fiscal year end and, therefore, different N-CSR reporting requirements.  A separate N-CSR will be filed for any series with a different fiscal year end, as appropriate.
BNY Mellon Ultra Short Income ETF
BNY Mellon Responsible Horizons Corporate Bond ETF
 

 
Item 1. Reports to Stockholders.
(a)
              
The following is a copy of the report transmitted to shareholders pursuant to Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1).
 
BNY
Mellon
ETF
Trust
ANNUAL
REPORT
June
30,
2023
BNY
Mellon
Ultra
Short
Income
ETF
Contents
The
Fund
Save
time.
Save
paper.
View
your
next
shareholder
report
online
as
soon
as
it’s
available.
Log
into
www.
im.bnymellon.com
and
sign
up
for
eCommunications.
It’s
simple
and
only
takes
a
few
minutes.
The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
Not
Bank-Guaranteed
May
Lose
Value
Discussion
of
Fund
Performance
3
Fund
Performance
6
Understanding
Your
Fund’s
Expenses
7
Statement
of
Investments
8
Statement
of
Assets
and
Liabilities
13
Statement
of
Operations
14
Statement
of
Changes
in
Net
Assets
15
Financial
Highlights
16
Notes
to
Financial
Statements
17
Report
of
Independent
Registered
Public
Accounting
Firm
25
Important
Tax
Information
26
Information
About
the
Review
and
Renewal
of
the
Fund’s
Management
and
Sub-Investment
Advisory
Agreements
27
Board
Members
Information
30
Officers
of
the
Trust
32
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
July
1,
2022,
through
June
30,
2023,
as
provided
by
Stephen
Murphy,
CFA,
and
Anthony
Honko,
portfolio
managers
employed
by
the
fund’s
sub-adviser,
Dreyfus,
a
division
of
Mellon
Investments
Corporation.
Market
and
Fund
Performance
Overview
For
the
12-month
period
ended
June
30,
2023,
BNY
Mellon
Ultra
Short
Income
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
3.64%.
1
In
comparison,
the
ICE
BofA
3-Month
U.S.
Treasury
Bill
Index
(the
“Index”),
the
fund’s
benchmark,
returned
3.59%
for
the
same
period.
2
Short-term,
fixed-income
yields
rose
during
the
period
as
interest
rates
rose.
The
fund
outperformed
the
Index
largely
as
a
result
of
its
reinvestment
of
maturing,
short-term,
fixed-rate
corporate
instruments
in
higher-yielding,
fixed-
and
floating-rate
assets.
The
Fund’s
Investment
Approach
The
fund
seeks
high
current
income
consistent
with
the
maintenance
of
liquidity
and
low
volatility
of
principal.
To
pursue
its
goal,
the
fund
normally
invests
at
least
80%
of
its
net
assets
in
investment-grade,
U.S.
dollar-denominated,
fixed,
variable,
and
floating-rate
debt
or
cash
equivalents.
The
fund
typically
seeks
to
maintain
an
effective
duration
of
one
year
or
less,
although,
under
certain
market
conditions,
such
as
in
periods
of
significant
volatility
in
interest
rates
and
spreads,
the
fund’s
duration
may
be
longer
than
one
year.
The
fund’s
portfolio,
under
normal
market
conditions,
will
have
an
average
credit
rating
of
at
least
A
or
the
equivalent.
The
fund’s
portfolio
managers
seek
to
achieve
what
they
believe
provides
the
optimal
portfolio
for
the
fund
in
terms
of
preservation
of
principal,
liquidity
and
high
current
income.
To
do
so,
the
portfolio
managers
use
a
top-down
and
bottom-up
investment
process,
and
leverage
the
breadth
and
depth
of
Dreyfus’
research
resources.
The
portfolio
managers
focus
on
preservation
of
principal
and
downside
protection,
by
proactively
monitoring
issuer
and
counterparty
risk,
and
ensure
appropriate
portfolio
liquidity
through
a
combination
of
overnight
investments
and
short-term,
highly
liquid
securities.
Inflation
Drives
Yields
Higher
Persistently
high
inflation
led
the
U.S.
Federal
Reserve
(the
“Fed”)
to
implement
a
series
of
aggressive
interest
rate
hikes,
raising
the
federal
funds
rate
by
a
total
of
3.50%
during
the
period.
Rising
rates
drove
bond
yields
sharply
higher,
with
the
one-year
Treasury
bill
increasing
nearly
3%
and
the
two-year
Treasury
bill
up
nearly
2%.
The
yield
curve
inverted
as
the
two-year
Treasury
rate
exceeded
the
10-year
Treasury
rate,
a
condition
widely
viewed
as
a
precursor
to
a
recession.
Credit
spreads
widened
amid
fears
of
a
marked
economic
slowdown.
Credit
spreads
refer
to
the
comparative
yields
of
bonds
of
different
credit
quality
but
the
same
maturity.
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
Rising
rates
caused
turmoil
in
the
regional
banking
industry,
leading
to
a
few
high-
profile
bank
failures
in
March
and
April
2023.
While
volatility
spiked
higher,
and
spreads
widened
sharply
in
the
banking
sector,
swift
action
by
federal
authorities
appeared
to
limit
the
impact,
reducing
stresses
and
easing
concerns.
Uncertainty
regarding
federal
debt
ceiling
negotiations
in
May
added
further
short-term
volatility,
which
ended
with
Congressional
agreement
to
raise
the
debt
ceiling.
For
the
period
as
a
whole,
while
long-term
U.S.
bond
prices
struggled
against
the
backdrop
of
rising
yields,
short-term
notes
and
floating-rate
instruments
produced
positive
returns.
Returns
Benefit
from
Reinvesting
in
Higher-Yielding
Instruments
The
fund
benefited
from
the
rising
yield
environment.
By
maintaining
a
duration
of
approximately
six
months
during
the
reporting
period,
we
positioned
the
fund
to
continually
reinvest
funds
from
maturing
assets
at
more
attractive
yields.
Approximately
two-thirds
of
the
fund’s
assets
were
invested
in
short-term
money
market
and
floating-
rate
securities.
Our
focus
on
higher-quality
corporate
credit
rated
A
or
better
enabled
the
fund
to
withstand
the
regional
banking
crisis
of
2023
relatively
well,
and
to
add
exposure
to
credits
in
the
banking
sector
at
more
attractive
spreads
at
the
height
of
the
turmoil.
Conversely,
the
fund’s
modest
exposure
to
longer-term,
fixed-rate
securities,
which
comprised
approximately
10%
to
15%
of
the
portfolio,
detracted
from
returns
relative
to
the
Index.
The
fund
maintained
those
longer-term
positions
for
diversification
and
as
a
hedge
against
the
possibility
of
declining
rates.
Expecting
Rates
to
Remain
Elevated
While
inflation
has
declined
from
an
annualized
rate
of
9.06%
in
June
2022
to
4.05%
as
of
May
2023,
it
remains
well
above
the
Fed
target
of
2%.
Accordingly,
while
the
pace
of
the
Fed’s
interest
rate
increases
has
slowed
in
2023,
we
expect
at
least
one
additional
increase
later
this
year.
Although
the
market
has
priced
in
an
expectation
for
rate
cuts
in
the
near
to
medium
term,
we
expect
the
Fed
to
maintain
rates
higher
for
longer
than
the
market
expects,
particularly
in
view
of
recent
labor
market
strength.
Until
we
see
a
likelihood
of
rate
reductions,
we
expect
to
maintain
the
fund’s
current
duration
position,
increasing
exposure
to
floating-rate
credit
as
attractive
opportunities
present
themselves.
We
may
also
seek
to
take
advantage
of
attractive
pricing
in
six-to-
nine
month
fixed-rate
commercial
paper.
July
17,
2023
1
Total
return
includes
reinvestment
of
dividends
and
any
capital
gains
paid.
A
fund’s
net
asset
value
(NAV)
is
the
sum
of
all
its
assets
less
any
liabilities,
divided
by
the
number
of
shares
outstanding.
ETFs
are
bought
and
sold
at
market
prices,
not
NAV,
therefore
an
investor’s
return
at
market
price
may
differ
from
NAV.
Past
performance
is
no
guarantee
of
future
results.
Share
price,
yield
and
investment
return
fluctuate
such
that
upon
redemption,
fund
shares
may
be
worth
more
or
less
than
their
original
cost.
2
Source:
FactSet
-
The
ICE
BofA
3-Month
U.S.
Treasury
Bill
Index
is
an
unmanaged
market
index
of
U.S.
Treasury
securities
maturing
in
90
days
that
assumes
reinvestment
of
all
income.
Investors
cannot
invest
directly
in
any
index.
ETFs
trade
like
stocks,
are
subject
to
investment
risk,
including
possible
loss
of
principal.
ETF
shares
are
listed
on
an
exchange,
and
shares
are
generally
purchased
and
sold
in
the
secondary
market
at
market
price.
At
times,
the
market
price
may
be
at
a
premium
or
discount
to
the
ETF’s
per
share
NAV.
In
addition,
ETFs
are
subject
to
the
risk
that
an
active
trading
5
market
for
an
ETF’s
shares
may
not
develop
or
be
maintained.
Buying
or
selling
ETF
shares
on
an
exchange
may
require
payment
of
brokerage
commissions.
Bonds
are
subject
generally
to
interest-rate,
credit,
liquidity
and
market
risks,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
Generally,
all
other
factors
being
equal,
bond
prices
are
inversely
related
to
interest-rate
changes,
and
rate
increases
can
cause
price
decline.
FUND
PERFORMANCE
(Unaudited)
6
Comparison
of
change
in
value
of
a
$10,000
investment
in
BNY
Mellon
Ultra
Short
Income
ETF
with
a
hypothetical
investment
of
$10,000
in
ICE
BofA
3-Month
U.S.
Treasury
Bill
Index.
Sources:
FactSet
Past
performance
is
not
predictive
of
future
performance.
The
above
graph
compares
a
hypothetical
$10,000
investment
made
in
BNY
Mellon
Ultra
Short
Income
ETF
on
8/9/21
to
a
hypothetical
investment
of
$10,000
made
in
the
Index
on
that
date
using
closing
market
price
return.
All
dividends
and
capital
gain
distributions
are
reinvested.
The
fund’s
performance
shown
in
the
line
graph
above
takes
into
account
all
applicable
fees
and
expenses.
The
ICE
BofA
3-Month
U.S.
Treasury
Bill
Index
is
an
unmanaged
market
index
of
U.S.
Treasury
securities
maturing
in
90
days
that
assumes
reinvestment
of
all
income.
Investors
cannot
invest
directly
in
any
index.
Further
information
relating
to
fund
performance,
including
expense
reimbursements,
if
applicable,
is
contained
in
the
Financial
Highlight
section
of
the
prospectus
and
elsewhere
in
this
report.
The
performance
data
quoted
represents
past
performance,
which
is
no
guarantee
of
future
results.
Share
price
and
investment
return
fluctuate
and
an
investor’s
shares
may
be
worth
more
or
less
than
original
cost
upon
redemption.
Current
performance
may
be
lower
or
higher
than
the
performance
quoted.
Go
to
www.
im.bnymellon.com
for
the
fund’s
most
recent
month-end
returns.
The
fund’s
performance
shown
in
the
graph
and
table
does
not
reflect
the
deduction
of
taxes
that
a
shareholder
would
pay
on
fund
distributions
or
the
redemption
of
fund
shares.
Average
Annual
Total
Returns
as
of
June
30,
2023
Inception
Date
1
Year
From
Inception
BNY
Mellon
Ultra
Short
Income
ETF
Net
Asset
Value
Return
8/9/21
3.64%
2.05%
Market
Price
Return
8/9/21
3.62%
2.02%
ICE
BofA
3-Month
U.S.
Treasury
Bill
Index
8/9/21
3.59%
3.76%
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
7
As
a
shareholder
of
the
fund,
you
pay
ongoing
expenses,
such
as
management
fees
and
other
expenses.
Using
the
information
below,
you
can
estimate
how
these
expenses
affect
your
investment
and
compare
them
with
the
expenses
of
other
funds.
For
more
information,
see
your
fund’s
prospectus
or
talk
to
your
financial
adviser.
Actual
Expenses
The
information
under
each
column
in
the
table
below
entitled
“Actual”
provides
information
about
on
how
much
a
$1,000
investment
would
be
worth
at
the
close
of
the
period,
assuming
net
asset
value
total
returns
and
actual
expenses.
You
may
use
the
information
in
these
columns,
together
with
the
amount
you
invested,
to
estimate
the
expenses
that
you
paid
over
the
period.
Simply
divide
your
account
value
by
$1,000
(for
example,
an
$8,600
account
value
divided
by
$1,000
=
8.6),
then
multiply
the
result
by
the
number
for
the
fund
under
the
heading
entitled
“Expenses
paid
for
the
period”
to
estimate
the
expenses
you
paid
on
your
account
during
this
period.
Hypothetical
Example
For
Comparison
Purposes
The
Securities
and
Exchange
Commission
(“SEC”)
has
established
guidelines
to
help
investors
assess
fund
expenses.
The
information
under
each
column
in
the
table
entitled
“Hypothetical”
provides
information
about
hypothetical
account
values
and
hypothetical
expenses
based
on
the
fund’s
actual
expense
ratio
and
an
assumed
rate
of
return
of
5%
per
year
before
expenses,
which
is
not
the
fund’s
actual
return.
The
hypothetical
account
values
and
expenses
may
not
be
used
to
estimate
the
actual
ending
account
balance
or
expenses
you
paid
for
the
period.
You
may
use
this
information
to
compare
the
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
To
do
so,
compare
this
5%
hypothetical
example
with
the
5%
hypothetical
examples
that
appear
in
the
shareholder
reports
of
the
other
funds.
Please
note
that
the
expenses
shown
in
the
table
are
meant
to
highlight
your
ongoing
costs
only
and
do
not
reflect
any
transactional
costs,
such
as
brokerage
commissions
paid
on
purchases
and
sales
of
fund
shares.
Therefore,
the
ending
account
values
and
expenses
paid
for
the
period
in
the
table
are
useful
in
comparing
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
In
addition,
if
these
transactional
costs
were
included,
your
costs
would
have
been
higher.
For
the
six
months
ended
June
30,
2023
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
six-month
period
ended
June
30,
2023.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
181/365.
Beginning
account
value
($)
Ending
account
value($)
Expense
paid
for
the
period
($)
Annualized
expense
ratios
for
the
period
(%)
Actual
Hypothetical
Actual
Hypothetical
Actual
(a)
Hypothetical
(a)
1,000.00
1,000.00
1,023.80
1,024.20
0.60
0.60
0.12
STATEMENT
OF
INVESTMENTS
June
30,
2023
8
Description
Principal
Amount
($)
Value
($)
Asset-Backed
Securities
7.8%
Ford
Credit
Auto
Lease
Trust,
Series
2021-B,
Class
A4,
0.40%,
12/15/2024
350,000
344,091
Ford
Credit
Floorplan
Master
Owner
Trust,
Series
2019-2,
Class
A,
3.06%,
4/15/2026
300,000
293,692
GMF
Floorplan
Owner
Revolving
Trust,
Series
2020-1,
Class
A,
0.68%,
8/15/2025
(a)
300,000
298,298
Honda
Auto
Receivables
Owner
Trust,
Series
2021-3,
Class
A3,
0.41%,
11/18/2025
292,211
281,309
Hyundai
Auto
Lease
Securitization
Trust,
Series
2021-C,
Class
A4,
0.48%,
9/15/2025
(a)
350,000
339,454
Kubota
Credit
Owner
Trust,
Series
2020-1A,
Class
A4,
2.26%,
7/15/2026
(a)
255,416
254,010
Oscar
US
Funding
XII
LLC,
Series
2021-1A,
Class
A3,
0.70%,
4/10/2025
(a)
197,049
193,106
World
Omni
Automobile
Lease
Securitization
Trust,
Series
2022-A,
Class
A3,
3.21%,
2/18/2025
300,000
294,444
Total
Asset-Backed
Securities
(cost
$2,374,756)
2,298,404
Commercial
Paper
35.4%
Australia
&
New
Zealand
Banking
Group
Ltd.,
5.35%,
8/28/2023
(a)
(b)
550,000
545,326
Bedford
Row
Funding
Corp.,
5.36%
(1
Month
SOFR
+
0.30%),
7/27/2023
(a)(c)
300,000
300,032
Collateralized
Commercial
Paper
V
Co.,
LLC,
5.31%
(1
Month
SOFR
+
0.25%),
8/10/2023
(c)
300,000
300,029
Federation
Caisses
Desjardins,
5.20%,
8/14/2023
(a)(b)
575,000
571,266
HSBC
Bank
PLC,
5.72%
(1
Month
SOFR
+
0.66%),
6/21/2024
(a)(c)
460,000
460,017
ING
Funding,
LLC,
5.14%,
9/01/2023
(b)
750,000
742,977
LMA
SA/LMA-Americas,
LLC
5.47%,
10/12/2023
(a)(b)
275,000
270,612
5.84%,
1/22/2024
(a)(b)
250,000
241,864
Manhattan
Asset
Funding
Co.,
LLC,
5.73%,
12/06/2023
(a)(b)
375,000
365,730
Mizuho
Bank
Ltd.,
5.10%,
7/25/2023
(a)(b)
850,000
846,996
Natixis
NY
Branch,
5.59%,
9/05/2023
(b)
750,000
742,789
Old
Line
Funding,
LLC,
5.56%
(1
Month
SOFR
+
0.50%),
3/04/2024
(a)(c)
275,000
275,000
Sheffield
Receivables
Corp.,
5.47%,
10/10/2023
(a)(b)
850,000
836,742
Skandinav
Enskilda
Bank,
5.81%
(1
Month
SOFR
+
0.75%),
8/02/2023
(a)(c)
850,000
850,469
Societe
Generale
SA,
5.89%,
3/13/2024
(a)(b)
675,000
647,615
Starbird
Funding
Corp.,
5.28%
(1
Month
SOFR
+
0.22%),
12/08/2023
(a)(c)
900,000
899,239
Swedbank
,
5.53%
(1
Month
SOFR
+
0.47%),
12/19/2023
(c)
900,000
900,466
Westpac
Banking
Corp.,
5.39%
(1
Month
SOFR
+
0.33%),
11/27/2023
(a)(c)
650,000
650,052
Total
Commercial
Paper
(cost
$10,449,306)
10,447,221
9
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
56.2%
Auto
Manufacturers
4.9%
American
Honda
Finance
Corp.,
2.90%,
2/16/2024
300,000
294,989
BMW
US
Capital
LLC,
5.47%
(3
Month
SOFRIX
+
0.38%),
8/12/2024
(a)(c)
300,000
299,335
General
Motors
Financial
Co.,
Inc.,
5.40%,
4/06/2026
250,000
247,215
PACCAR
Financial
Corp.,
3.55%,
8/11/2025
300,000
291,086
Toyota
Motor
Credit
Corp.,
5.34%
(3
Month
SOFR
+
0.32%),
1/13/2025
(c)
300,000
298,093
1,430,718
Banks
33.6%
ANZ
New
Zealand
Int'l
Ltd.,
5.69%
(3
Month
SOFR
+
0.60%),
2/18/2025
(a)(c)
300,000
299,434
ASB
Bank
Ltd.,
3.13%,
5/23/2024
(a)
350,000
342,058
Banco
Santander
SA,
6.33%
(3
Month
SOFR
+
1.24%),
5/24/2024
(c)
350,000
351,412
Bank
of
Montreal
5.44%
(3
Month
SOFRIX
+
0.35%),
12/08/2023
(c)
350,000
349,905
6.15%
(3
Month
SOFRIX
+
1.06%),
6/07/2025
(c)
350,000
351,265
Bank
of
Nova
Scotia
(The),
5.47%
(3
Month
SOFR
+
0.46%),
1/10/2025
(c)
300,000
298,161
Canadian
Imperial
Bank
of
Commerce
5.49%
(3
Month
SOFRIX
+
0.40%),
12/14/2023
(c)
300,000
299,721
3.95%,
8/04/2025
275,000
265,947
Citigroup,
Inc.,
5.75%
(3
Month
SOFR
+
0.67%),
5/01/2025
(c)
300,000
299,074
Commonwealth
Bank
of
Australia,
5.84%
(3
Month
SOFR
+
0.75%),
3/13/2026
(a)(c)
350,000
349,456
Goldman
Sachs
Group,
Inc.
(The),
5.75%
(3
Month
SOFR
+
0.70%),
1/24/2025
(c)
200,000
199,715
HSBC
Holdings
PLC,
5.67%
(3
Month
SOFR
+
0.58%),
11/22/2024
(c)
350,000
348,709
JPMorgan
Chase
&
Co.,
6.38%
(3
Month
SOFR
+
1.32%),
4/26/2026
(c)
300,000
302,160
Keybank
NA/Cleveland
Oh,
4.70%,
1/26/2026
300,000
279,450
Manufacturers
&
Traders
Trust
Co.,
4.65%,
1/27/2026
300,000
286,705
Mitsubishi
UFJ
Financial
Group,
Inc.,
6.47%
(3
Month
SOFR
+
1.39%),
9/12/2025
(c)
350,000
352,023
Morgan
Stanley,
5.69%
(3
Month
SOFR
+
0.63%),
1/24/2025
(c)
300,000
299,489
National
Australia
Bank
Ltd.,
5.40%
(3
Month
SOFR
+
0.38%),
1/12/2025
(a)(c)
300,000
299,232
National
Bank
of
Canada,
5.25%,
1/17/2025
300,000
297,427
Natwest
Markets
PLC,
5.62%
(3
Month
SOFR
+
0.53%),
8/12/2024
(a)(c)
350,000
347,965
Nordea
Bank
Abp
,
0.63%,
5/24/2024
(a)
300,000
286,005
PNC
Financial
Services
Group,
Inc.
(The),
3.50%,
1/23/2024
300,000
296,284
Royal
Bank
of
Canada,
Series
G,
5.49%
(3
Month
SOFRIX
+
0.44%),
1/21/2025
(c)
300,000
298,669
Standard
Chartered
PLC,
6.83%
(3
Month
SOFR
+
1.74%),
3/30/2026
(a)(c)
350,000
352,630
State
Street
Corp.,
3.55%,
8/18/2025
98,000
94,462
STATEMENT
OF
INVESTMENTS
(continued)
10
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
56.2%
(continued)
Banks
33.6%
(continued)
Sumitomo
Mitsui
Financial
Group,
Inc.,
0.51%,
1/12/2024
300,000
291,727
Sumitomo
Mitsui
Trust
Bank
Ltd.,
5.53%
(3
Month
SOFR
+
0.44%),
9/16/2024
(a)(c)
300,000
298,723
Svenska
Handelsbanken
AB,
3.90%,
11/20/2023
300,000
297,511
Toronto-Dominion
Bank
(The),
5.44%
(3
Month
SOFR
+
0.35%),
9/10/2024
(c)
300,000
299,119
Truist
Bank,
3.20%,
4/01/2024
300,000
294,086
UBS
AG,
0.45%,
2/09/2024
(a)
300,000
289,993
Wells
Fargo
&
Co.,
3.00%,
2/19/2025
300,000
288,085
Westpac
Banking
Corp.,
5.39%
(3
Month
SOFR
+
0.30%),
11/18/2024
(c)
300,000
298,917
9,905,519
Beverages
0.8%
Diageo
Capital
PLC,
3.50%,
9/18/2023
250,000
248,865
248,865
Computers
1.0%
International
Business
Machines
Corp.,
4.00%,
7/27/2025
300,000
293,336
293,336
Diversified
Financial
Services
3.0%
American
Express
Co.
3.40%,
2/22/2024
300,000
295,601
5.85%
(3
Month
SOFR
+
0.76%),
2/13/2026
(c)
250,000
249,516
Charles
Schwab
Corp.
(The),
5.59%
(3
Month
SOFRIX
+
0.50%),
3/18/2024
(c)
350,000
349,128
894,245
Food
1.0%
Mondelez
International,
Inc.,
2.13%,
3/17/2024
300,000
292,720
292,720
Insurance
0.9%
Prudential
Financial,
Inc.,
1.50%,
3/10/2026
300,000
274,196
274,196
Machinery-Construction
&
Mining
1.0%
Caterpillar
Financial
Services
Corp.,
5.18%
(3
Month
SOFR
+
0.17%),
1/10/2024
(c)
300,000
299,853
299,853
Machinery-Diversified
2.0%
John
Deere
Capital
Corp.
0.45%,
1/17/2024
300,000
291,950
4.80%,
1/09/2026
300,000
299,028
590,978
Oil
&
Gas
1.0%
BP
Capital
Markets
America,
Inc.,
3.41%,
2/11/2026
300,000
288,383
288,383
11
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
56.2%
(continued)
Pharmaceuticals
2.8%
AstraZeneca
Finance
LLC,
0.70%,
5/28/2024
300,000
287,535
GlaxoSmithKline
Capital
PLC,
3.00%,
6/01/2024
300,000
293,209
Pfizer
Investment
Enterprises
Pte
Ltd.,
4.45%,
5/19/2026
250,000
247,060
827,804
Retail
1.0%
Walmart,
Inc.,
3.90%,
9/09/2025
300,000
294,104
294,104
Semiconductors
1.0%
Intel
Corp.,
3.70%,
7/29/2025
300,000
291,850
291,850
Software
1.0%
Salesforce,
Inc.,
0.63%,
7/15/2024
300,000
285,672
285,672
Telecommunications
1.2%
Verizon
Communications,
Inc.,
5.59%
(3
Month
SOFRIX
+
0.50%),
3/22/2024
(c)
350,000
350,063
350,063
Total
Corporate
Bonds
(cost
$16,816,520)
16,568,306
Shares
Investment
Companies
0.1%
Registered
Investment
Companies
0.1%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.07%
(d)(e)
(cost
$39,339)
39,339
39,339
Total
Investments
(cost
$29,679,921)
99.5%
29,353,270
Cash
and
Receivables
(Net)
0.5%
144,877
Net
Assets
100.0%
29,498,147
SOFR—Secured
Overnight
Financing
Rate
SOFRIX—Secured
Overnight
Financing
Rate
Index
(a)
Security
exempt
from
registration
pursuant
to
Rule
144A
under
the
Securities
Act
of
1933.
These
securities
may
be
resold
in
transactions
exempt
from
registration,
normally
to
qualified
institutional
buyers.
At
June
30,
2023,
these
securities
were
valued
at
$12,010,659
or
40.72%
of
net
assets.
(b)
Security
is
a
discount
security.
Income
is
recognized
through
the
accretion
of
discount.
(c)
Variable
rate
security
-
rate
shown
is
the
interest
rate
in
effect
at
period
end.
Security
description
also
includes
the
reference
rate
and
spread
if
published
and
available.
(d)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(e)
The
rate
shown
is
the
1-day
yield
as
of
June
30,
2023.
STATEMENT
OF
INVESTMENTS
(continued)
12
See
Notes
to
Financial
Statements
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
June
30,
2023
are
as
follows:
Description
Value
6/30/22
Purchases
($)
1
Sales
($)
Value
6/30/23
Dividends/
Distributions
($)
Investment
Companies
0.1%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
119,646
14,659,356
(14,739,663)
39,339
9,553
Total
0.1%
119,646
14,659,356
(14,739,663)
39,339
9,553
1
Includes
reinvested
dividends/distributions.
Portfolio
Summary
(Unaudited)
Value
(%)
Financial
80.7
Consumer,
Cyclical
5.9
Consumer,
Non-cyclical
4.6
Industrial
3.0
Technology
3.0
Communications
1.2
Energy
1.0
Registered
Investment
Companies
0.1
99.5
Based
on
net
assets.
STATEMENT
OF
ASSETS
AND
LIABILITIES
June
30,
2023
13
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
Unaffiliated
issuers
29,640,582
29,313,931‌
Affiliated
issuers
39,339
39,339‌
Interest
receivable
147,123‌
Dividends
receivable
658‌
29,501,051‌
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
2,904‌
2,904‌
Net
Assets
($)
29,498,147‌
Composition
of
Net
Assets
($):
Paid-in
capital
29,961,204‌
Total
distributable
earnings
(loss)
(463,057‌)
Net
Assets
($)
29,498,147‌
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
600,001‌
Net
asset
value
per
share
49.16‌
Market
price
per
share
49.15‌
STATEMENT
OF
OPERATIONS
Year
Ended
June
30,
2023
14
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Affiliated
issuers
9,553‌
Interest
910,939‌
Total
Income
920,492‌
Expenses:
Management
fee—Note
3(a)
33,344‌
Total
Expenses
33,344‌
Net
Investment
Income
887,148‌
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
(9,700‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
117,584‌
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
107,884‌
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
995,032‌
STATEMENT
OF
CHANGES
IN
NET
ASSETS
15
See
Notes
to
Financial
Statements
Year
Ended
June
30,
2023
For
the
Period
from
August
11,
2021
(a)
to
June
30,
2022
Operations
($):
Net
investment
income
887,148‌
94,676‌
Net
realized
gain
(loss)
on
investments
(9,700‌)
(82,212‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
117,584‌
(444,235‌)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
995,032‌
(431,771‌)
Distributions
($):
Distributions
to
shareholders
(878,254‌)
(148,064‌)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
4,886,067‌
29,996,289‌
Cost
of
shares
redeemed
(2,436,261‌)
(2,488,871‌)
Transaction
fees—Note
5
732‌
3,248‌
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
2,450,538‌
27,510,666‌
Total
Increase
(Decrease)
in
Net
Assets
2,567,316‌
26,930,831‌
Net
Assets
($):
Beginning
of
Period
26,930,831‌
—‌
End
of
Period
29,498,147‌
26,930,831‌
Changes
in
Shares
Outstanding:
Shares
sold
100,000‌
600,001‌
Shares
redeemed
(50,000‌)
(50,000‌)
Net
Increase
(Decrease)
in
Shares
Outstanding
50,000‌
550,001‌
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
16
The
following
table
describes
the
performance
for
the
fiscal
periods
indicated
and
these
figures
have
been
derived
from
the
fund’s
financial
statements.
See
Notes
to
Financial
Statements
Year
Ended
June
30,
2023
For
the
Period
from
August
11,
2021
(a)
to
June
30,
2022
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
48.97‌
50.00‌
Investment
Operations:
Net
investment
income
(b)
1.56‌
0.17‌
Net
realized
and
unrealized
gain
(loss)
on
investments
0.18‌
(0.94‌)
Total
from
Investment
Operations
1.74‌
(0.77‌)
Distributions:
Dividends
from
net
investment
income
(1.55‌)
(0.27‌)
Transaction
fees
(b)
0.00‌
(c)
0.01‌
Net
asset
value,
end
of
period
49.16‌
48.97‌
Market
price,
end
of
period
(d)
49.15‌
48.96‌
Net
Asset
Value
Total
Return
(%)
(e)
3.64‌
(1.54‌)
(f)
Market
Price
Total
Return
(%)
(e)
3.62‌
(1.55‌)
(f)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.12‌
0.12‌
(g)
Ratio
of
net
investment
income
to
average
net
assets
3.19‌
0.39‌
(g)
Portfolio
Turnover
Rate
(h)
20.55‌
43.10‌
Net
Assets,
end
of
period
($
x
1,000)
29,498‌
26,931‌
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
Amount
represents
less
than
$0.01
per
share.
(d)
The
mean
between
the
last
bid
and
ask
prices.
(e)
Net
asset
value
total
return
is
calculated
assuming
an
initial
investment
made
at
the
net
asset
value
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
net
asset
value
during
the
period,
and
redemption
at
net
asset
value
on
the
last
day
of
the
period.
Net
asset
value
total
return
includes
adjustments
in
accordance
with
accounting
principles
generally
accepted
in
the
United
States
of
America
and
as
such,
the
net
asset
value
for
financial
reporting
purposes
and
the
returns
based
upon
those
net
asset
values
may
differ
from
the
net
asset
value
and
returns
for
shareholder
transactions.
Market
price
total
return
is
calculated
assuming
an
initial
investment
made
at
the
market
price
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
market
price
during
the
period,
and
sale
at
the
market
price
on
the
last
day
of
the
period.
Total
investment
returns
calculated
for
a
period
of
less
than
one
year
are
not
annualized.
(f)
The
net
asset
value
total
return
and
the
market
price
total
return
is
calculated
from
fund
inception.
(g)
Annualized.
(h)
Portfolio
turnover
rate
is
not
annualized
for
periods
less
than
one
year,
if
applicable,
and
does
not
include
securities
received
or
delivered
from
processing
creations
or
redemptions.
NOTES
TO
FINANCIAL
STATEMENTS
17
NOTE
1—Organization:
BNY
Mellon
Ultra
Short
Income
ETF (the “fund”) is a
separate
diversified series
of
BNY
Mellon
ETF
Trust
(the
“Trust”),
which is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-ended
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
seventeen
series,
including
the
fund.
The
investment
objective
of
the
fund
is
to
seek
high
current
income
consistent
with
the
maintenance
of
liquidity
and
low
volatility
of
principal.
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
a
wholly-owned
subsidiary
of
The
Bank
of
New
York
Mellon
Corporation
(“BNY
Mellon”),
serves
as
the
fund’s
investment
adviser. Dreyfus,
a
division
of
Mellon
Investments
Corporation (the
“Sub-Adviser”),
an
indirect wholly-
owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-adviser.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a
wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“fund’s
Shares.”
The
fund’s
Shares
are
listed
and
traded
on
NYSE
Arca,
Inc.
The
market
price
of
each
Share
may
differ
to
some
degree
from
the
fund’s
net
asset
value
(“NAV”).
Unlike
conventional
mutual
funds,
the
fund
issues
and
redeems
Shares
on
a
continuous
basis,
at
NAV,
only
in
a
large
specified
number
of
Shares,
each
called
a
“Creation
Unit.”
Creation
Units
are
issued
and
redeemed
principally
in
exchange
for
the
deposit
or
delivery
of
a
basket
of
securities.
Except
when
aggregated
in
Creation
Units
by
Authorized
Participants,
the
Shares
are
not
individually
redeemable
securities
of
the
fund.
Individual
fund
Shares
may
only
be
purchased
and
sold
on
the
NYSE
Arca,
Inc.,
other
national
securities
exchanges,
electronic
crossing
networks
and
other
alternative
trading
systems
through
your
broker-dealer
at
market
prices.
Because
fund
Shares
trade
at
market
prices
rather
than
at
NAV,
fund
Shares
may
trade
at
a
price
greater
than
NAV
(premium)
or
less
than
NAV
(discount).
When
buying
or
selling
Shares
in
the
secondary
market,
you
may
incur
costs
attributable
to
the
difference
between
the
highest
price
a
buyer
is
willing
to
pay
to
purchase
Shares
of
the
fund
(bid)
and
the
lowest
price
a
seller
is
willing
to
accept
for
Shares
of
the
fund
(ask). 
NOTE
2—Significant
Accounting
Policies: 
The
Financial
Accounting
Standards
Board
(“FASB”)
Accounting
Standards
Codification
(“ASC”)
is
the
exclusive
reference
of
authoritative
U.S.
generally
accepted
accounting
principles
(“GAAP”)
recognized
by
the
FASB
to
be
applied
by
nongovernmental
entities.
Rules
and
interpretive
releases
of
the
SEC
under
authority
of
federal
laws
are
also
sources
of
authoritative
GAAP
for
SEC
registrants. The
fund
is an
investment
company
and
applies
the
accounting
and
reporting
guidance
of
the
FASB
ASC
Topic
946
Financial
Services-Investment
Companies. The
fund’s
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
18
financial
statements
are
prepared
in
accordance
with
GAAP,
which
may
require
the
use
of
management
estimates
and
assumptions.
Actual
results
could
differ
from
those
estimates.  
The
Trust
accounts
separately
for
the
assets,
liabilities
and
operations
of
each
series.
Expenses
directly
attributable
to
each
series
are
charged
to
that
series’
operations;
expenses
which
are
applicable
to
all
series
are
allocated
among
them
on
a
pro
rata
basis.
The
Trust
enters
into
contracts
that
contain
a
variety
of
indemnifications.
The
fund’s
maximum
exposure
under
these
arrangements
is
unknown.
The
fund
does
not
anticipate
recognizing
any
loss
related
to
these
arrangements. 
(a)
Portfolio
valuation:
The
fair
value
of
a
financial
instrument
is
the
amount
that
would
be
received
to
sell
an
asset
or
paid
to
transfer
a
liability
in
an
orderly
transaction
between
market
participants
at
the
measurement
date
(i.e.,
the
exit
price).
GAAP
establishes
a
fair
value
hierarchy
that
prioritizes
the
inputs
of
valuation
techniques
used
to
measure
fair
value.
This
hierarchy
gives
the
highest
priority
to
unadjusted
quoted
prices
in
active
markets
for
identical
assets
or
liabilities
(Level
1
measurements)
and
the
lowest
priority
to
unobservable
inputs
(Level
3
measurements).
Additionally,
GAAP
provides
guidance
on
determining
whether
the
volume
and
activity
in
a
market
has
decreased
significantly
and
whether
such
a
decrease
in
activity
results
in
transactions
that
are
not
orderly.
GAAP
requires
enhanced
disclosures
around
valuation
inputs
and
techniques
used
during
annual
and
interim
periods.
Various
inputs
are
used
in
determining
the
value
of
the
fund’s
investments
relating
to
fair
value
measurements.
These
inputs
are
summarized
in
the
three
broad
levels
listed
below:
Level
1
unadjusted
quoted
prices
in
active
markets
for
identical
investments.
Level
2
other
significant
observable
inputs
(including
quoted
prices
for
similar 
investments,
interest
rates,
prepayment
speeds,
credit
risk,
etc.).
Level
3
significant
unobservable
inputs
(including
the
fund’s
own
assumptions
in
determining
the
fair
value
of
investments).
The
inputs
or
methodology
used
for
valuing
securities
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
those
securities.
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value
and
are
generally
categorized
within
Level 1
of
the
fair
value
hierarchy.
19
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
debt
securities
excluding
short-term
investments
(other
than
U.S.
Treasury
Bills)
are
valued
each
business
day
by
one
or
more
independent
pricing
services
(each,
a
“Service”)
approved
by the Board.
Investments
for
which
quoted
bid
prices
are
readily
available
and
are
representative
of
the
bid
side
of
the
market
in
the
judgment
of
a
Service
are
valued
at
the
mean
between
the
quoted
bid
prices
(as
obtained
by
a
Service
from
dealers
in
such
securities)
and
asked
prices
(as
calculated
by
a
Service
based
upon
its
evaluation
of
the
market
for
such
securities).
Securities
are
valued
as
determined
by
a
Service,
based
on
methods
which
include
consideration
of
the
following:
yields
or
prices
of
securities
of
comparable
quality,
coupon,
maturity
and
type;
indications
as
to
values
from
dealers;
and
general
market
conditions.
Each
Service
and
independent
valuation
firm
is
engaged
under
the
general
oversight
of
the
Board.
Overnight
and
certain
other
short-term
debt
instruments
(excluding
U.S.
Treasury
Bills)
will
be
valued
by
the
amortized
cost
method,
which
approximates
value,
unless
a
Service
provides
a
valuation
for
such
security
or,
in
the
opinion
of
the
Board
or
a
committee
or
other
persons
designated
by
the
Board,
the
amortized
cost
method
would
not
represent
fair
value. These
securities
are
generally
categorized
within
Level
2
of
the
fair
value
hierarchy.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
The
table
below
summarizes
the
inputs
used
as
of June
30,
2023
in
valuing
the
fund’s
investments:
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
20
Fair
Value
Measurements
(b) Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-
dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
(c)
Affiliated
issuers:
Investments
in
other
investment
companies
advised
by
the
Adviser
are
defined
as
“affiliated”
under
the
Act. 
(d)
Market
Risk:
The
value
of
the
securities
in
which
the
fund
invests
may
be
affected
by
political,
regulatory,
economic
and
social
developments,
and
developments
that
impact
specific
economic
sectors,
industries
or
segments
of
the
market.
The
value
of
a
security
may
also
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
company
or
industry,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
the
general
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates,
changes
to
inflation,
adverse
changes
to
credit
markets
or
adverse
investor
sentiment
generally.
In
addition,
turbulence
in
financial
markets
and
reduced
liquidity
in
equity,
credit
and/or
fixed
income
markets
may
negatively
affect
many
issuers,
which
could
adversely
affect
the
fund.
Global
economies
and
financial
markets
are
becoming
increasingly
interconnected,
and
conditions
and
events
in
one
country,
region
or
financial
market
may
adversely
impact
issuers
in
a
different
country,
region
or
financial
market.
These
risks
may
be
magnified
if
certain
events
or
developments
adversely
interrupt
the
global
supply
chain;
in
these
and
other
circumstances,
such
risks
might
affect
companies
world-wide.
Recent
examples
include
pandemic
risks
related
to
COVID-19
and
aggressive
measures
taken
world-wide
in
response
by
governments,
including
closing
borders,
restricting
international
and
domestic
travel,
and
the
imposition
of
prolonged
quarantines
of
large
populations,
and
by
businesses,
including
changes
to
operations
and
reducing
staff.
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
Asset-Backed
Securities
2,298,404
2,298,404
Commercial
Paper
10,447,221
10,447,221
Corporate
Bonds
16,568,306
16,568,306
Investment
Companies
39,339
39,339
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
21
Debt
Risk:
The
fund
invests
in
debt
securities.
Failure
of
an
issuer
of
the
debt
securities
to
make
timely
interest
or
principal
payments,
or
a
decline
or
the
perception
of
a
decline
in
the
credit
quality
of
a
debt
security,
can
cause
the
debt
security’s
price
to
fall,
potentially
lowering
the
fund’s
share
price.
In
addition,
the
value
of
debt
securities
may
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
issuer,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates
or
adverse
investor
sentiment.
They
may
also
decline
because
of
factors
that
affect
a
particular
industry.
Commercial
Paper
Risk:
Commercial
paper
is
a
short-term
obligation
with
a
maturity
generally
ranging
from
one
to
270
days
and
is
issued
by
U.S.
or
foreign
companies
or
other
entities
in
order
to
finance
their
current
operations.
Such
investments
are
unsecured
and
usually
discounted
from
their
value
at
maturity.
The
value
of
commercial
paper
may
be
affected
by
changes
in
the
credit
rating
or
financial
condition
of
the
issuing
entities
and
will
tend
to
fall
when
interest
rates
rise
and
rise
when
interest
rates
fall.
(e)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions
are
recorded
on
the
ex-dividend
date.
Dividends
from
net
investment
income
are
normally
declared
and
paid
on
a
monthly
basis.
Dividends
from
net
realized
capital
gains,
if
any,
are
normally
declared
and
paid
annually,
but
the
fund
may
make
distributions
on
a
more
frequent
basis
to
comply
with
the
distribution
requirements
of
the
Internal
Revenue
Code
of
1986,
as
amended
(the
“Code”).
To
the
extent
that
net
realized
capital
gains
can
be
offset
by
capital
loss
carryovers
of
a
fund,
it
is
the
policy
of
the
fund
not
to
distribute
such
gains.
Income
and
capital
gain
distributions
are
determined
in
accordance
with
income
tax
regulations,
which
may
differ
from
GAAP.
(f)
Federal
income
taxes:
It
is
the
policy
of
the
fund
to
continue to
qualify
as
a
regulated
investment
company,
if
such
qualification
is
in
the
best
interests
of
its
shareholders,
by
complying
with
the
applicable
provisions
of
the
Code,
and
to
make
distributions
of
taxable
income
and
net
realized
capital
gain sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
As
of
and
during
the period
ended June
30,
2023,
the
fund
did
not
have
any
liabilities
for
any
uncertain
tax
positions.
The
fund
recognizes
interest
and
penalties,
if
any,
related
to
uncertain
tax
positions
as
income
tax
expense
in
the
Statement
of
Operations.
During
the period
ended June
30,
2023,
the
fund
did
not
incur
any
interest
or
penalties.
Each
tax
year
in
the
two-year
period
ended
June
30,
2023
remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities.
At June
30,
2023,
the
components
of
accumulated
earnings
on
a
tax
basis
were
as
follows:
undistributed
ordinary
income
$113,069,
accumulated
capital
losses
$156,066, and
unrealized depreciation
$420,060.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
22
The
fund is
permitted
to
carry
forward
capital
losses
for
an
unlimited
period.
Furthermore,
capital
loss
carryovers
retain
their
character
as
either
short-term
or
long-
term
capital
losses.
The
accumulated
capital
loss
carryover
is
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
June
30,
2023.
The
fund
has
$105,384
of
short-term
capital
losses
and
$50,682
of
long-
term
capital
losses
which
can
be
carried
forward
for
an
unlimited
period.
The
tax
character
of
distributions
paid
to
shareholders
during
the
fiscal
years
ended
June
30,
2023
and
June
30,
2022
were
as
follows:
ordinary
income
$878,254
and
$148,064,
respectively.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.12%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expense,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
June
30,
2023,
there
was
no
reduction
in
expenses
pursuant
to
the
undertaking.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Sub-Adviser
serves
as
the
fund’s
sub-adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
percentage
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser
has
obtained
an
exemptive
order
from
the
SEC
(the
“Order”),
upon
which
the
fund
may
rely,
to
use
a
manager
of
managers
approach
that
permits
the
Adviser,
subject
to
certain
conditions
and
approval
by
the
Board,
to
enter
into
and
materially
amend
sub-investment
advisory
agreements
with
one
or
more
sub-advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-advisory
fee
paid
by
the
Adviser
to
a
Sub-Adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-advisory
fee
payable
by
the
Adviser
separately
to
a
Sub-Adviser
that
is
a
wholly-owned
subsidiary
(as
defined
in
the
1940
Act)
of
BNY
Mellon
in
documents
filed
with
the
SEC
and
23
provided
to
shareholders;
such
fees
are
to
be
aggregated
with
fees
payable
to
the
Adviser.
The
Adviser
has
ultimate
responsibility
(subject
to
oversight
by
the
Board)
to
supervise
any
Sub-Adviser
and
recommend
the
hiring,
termination,
and
replacement
of
any
Sub-Adviser
to
the
Board.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
rate
of
0.06%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser,
and
not
the
fund,
pays
the
Sub-Adviser
fee
rate.
(b)
The
fund
has
an
arrangement
with
The
Bank
of
New
York
Mellon
(the
“Custodian”),
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser, whereby
the
fund
will
receive
interest
income
or
be
charged
overdraft
fees
when
cash
balances
are
maintained.
For
financial
reporting
purposes,
the
fund
includes
this
interest
income
and
overdraft
fees,
if
any,
as
interest
income
in
the
Statement
of
Operations.
The
components
of
“Due
to
BNY
Mellon
ETF Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fee
of $2,904.
(c)
Each
Board
member
serves
as
a
Board
member
of
each
fund
within
the
Trust.
The
Board
members
are
not
compensated
directly
by
the
fund.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fee
paid
to
the
Adviser
by
the
fund.
The
quarterly
fees
are
paid
by
the
Adviser
from
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Trust,
including
the
fund.
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
(including
paydowns,
if
any)
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions,
during
the
period
ended
June
30,
2023, amounted
to $6,778,498
and
$3,649,997,
respectively.
At June
30,
2023,
the
cost
of
investments
for
federal
income
tax
purposes
was
$29,773,330;
accordingly,
accumulated
net
unrealized
depreciation on
investments
for
federal
income
tax
purposes was
$420,060,
consisting
of
gross
appreciation
of
$14,552
and
gross
depreciation
of
$434,612.
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
24
in-kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
As
of
June
30,
2023,
BNY
Mellon
held
499,001
shares
of
the
fund.
In-kind
Redemptions:
For
financial
reporting
purposes,
in-kind
redemptions
are
treated
as
sales
of
securities
resulting
in
realized
capital
gains
or
losses
to
the
fund.
Because
such
gains
or
losses
are
not
taxable
to
the
fund
and
are
not
distributed
to
existing
fund
shareholders,
the
gains
or
losses
are
reclassified
from
accumulated
net
realized
gain
(loss)
to
paid-in
capital
at
the
end
of
the
fund’s
tax
year.
These
reclassifications
have
no
effect
on
net
assets
or
net
asset
value
per
share.
During
the
year
ended
June
30,
2023,
the
fund
had
no
in-kind
transactions.
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
25
To
the
Shareholders
and
the
Board
of
Trustees
of
BNY
Mellon
Ultra
Short
Income
ETF
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
BNY
Mellon
Ultra
Short
Income
ETF
(the
“Fund”)
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust
(the
“Trust”)),
including
the
statement
of
investments,
as
of
June
30,
2023,
and
the
related
statement
of
operations
for
the
year
then
ended,
the
statements
of
changes
in
net
assets
and
the
financial
highlights
for
the
year
ended
June
30,
2023
and
the
period
from
August
11,
2021
(commencement
of
operations)
through
June
30,
2022
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Fund
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust)
at
June
30,
2023,
the
results
of
its
operations
for
the
year
then
ended,
the
changes
in
its
net
assets
and
its
financial
highlights
for
the
year
ended
June
30,
2023
and
the
period
from
August
11,
2021
(commencement
of
operations)
through
June
30,
2022,
in
conformity
with
U.S.
generally
accepted
accounting
principles.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Trust’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Fund’s
financial
statements
based
on
our
audits.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
(“PCAOB”)
and
are
required
to
be
independent
with
respect
to
the
Trust
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
conducted
our
audits
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audit
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Trust
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
the
Trust’s
internal
control
over
financial
reporting.
As
part
of
our
audits,
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Trust’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audits
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
June
30,
2023,
by
correspondence
with
the
custodian,
brokers
and
others;
when
replies
were
not
received
from
brokers
and
others,
we
performed
other
auditing
procedures.
Our
audits
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
We
believe
that
our
audits
provide
a
reasonable
basis
for
our
opinion.
We
have
served
as
the
auditor
of
one
or
more
investment
companies
in
the
BNY
Mellon
Family
of
Funds
since
at
least
1957,
but
we
are
unable
to
determine
the
specific
year.
New
York,
New
York
August
21,
2023
IMPORTANT
TAX
INFORMATION
(Unaudited)
26
Form
1099-DIV,
Form
1042-S
and
other
year–end
tax
information
provide
shareholders
with
actual
calendar
year
amounts
that
should
be
included
in
their
tax
returns.
Shareholders
should
consult
their
tax
advisers.
The
following
distribution
information
is
being
provided
as
required
by
the
Internal
Revenue
Code
or
to
meet
a
specific
state’s
requirement.
The
fund
designates
the
following
amounts
or,
if
subsequently
determined
to
be
different,
the
maximum
amount
allowable
for
its
fiscal
year
ended June
30,
2023:
For
federal
tax
purposes
the
fund
hereby
reports
71.17%
of
ordinary
income
dividends
paid
during
the
fiscal
year
ended
June
30,
2023 as
qualifying
interest
related
dividends.
INFORMATION
ABOUT
THE
REVIEW
AND
RENEWAL
OF
THE
FUND’S
MANAGEMENT
AND
SUB-INVESTMENT
ADVISORY
AGREEMENTS
(Unaudited)
27
At
a
meeting
held
February
8,
2023,
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended,
evaluated
(i)
a
proposal
to
continue
the
Management
Agreement
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”)
with
respect
to
the
BNY
Mellon
Ultra
Short
Income
ETF
(the
“fund”);
and
(ii)
a
proposal
to
continue
the
sub-investment
advisory
agreement
between
the
Adviser
and
Mellon
Investments
Corporation
(the
“Sub-
Adviser”),
an
affiliate
of
the
Adviser,
pursuant
to
which
Dreyfus,
a
division
of
the
Sub-Adviser,
provides
day-to-day
management
of
the
fund’s
investments
(each
of
the
Management
Agreement
and
the
sub-investment
advisory
agreement,
an
“Agreement,”
and
collectively,
the
“Agreements”).
The
Trustees
also
met
separately
to
consider
the
Agreements.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
To
evaluate
the
Agreements,
the
Board
requested,
and
the
Adviser
and
the
Sub-Adviser
provided,
such
materials
as
the
Board,
with
the
advice
of
counsel,
deemed
reasonably
necessary.
In
addition,
the
Board
considered
information
it
reviewed
at
other
Board
and
Board
committee
meetings.
In
deciding
whether
to
approve
the
Agreements,
the
Board
considered
various
factors,
including
the
(i)
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
Sub-Adviser
under
each
respective
Agreement,
(ii)
investment
performance
of
the
fund,
(iii)
profits
realized
by
the
Adviser
and
its
affiliates
from
its
relationship
with
the
fund,
(iv)
fees
charged
to
comparable
funds,
(v)
other
benefits
to
the
Adviser,
Sub-Adviser
and/or
their
affiliates,
and
(vi)
extent
to
which
economies
of
scale
would
be
shared
as
the
fund
grows.
The
Board
considered
the
Agreements
for
the
fund
and
the
engagement
of
the
Adviser
and
the
Sub-Adviser
separately.
The
Board
reviewed
reports
prepared
by
Broadridge
Financial
Solutions,
Inc.
(“Broadridge”),
an
independent
provider
of
investment
company
data,
which
included
information
(i)
comparing
the
fund’s
performance
with
the
performance
of
a
group
of
other
actively-managed
ultrashort
bond
exchange
traded
funds
(“ETFs”)
(the
“Performance
Group”)
and
with
a
broader
group
of
retail
and
institutional
ultrashort
bond
funds
and
ETFs
(the
“Performance
Universe”)
for
the
one-year
period
ended
December
31,
2022;
and
(ii)
comparing
the
fund’s
contractual
management
fees
and
total
expenses
with
a
group
of
other
actively-managed
ultrashort
bond
ETFs
(the
“Expense
Group”)
and,
with
respect
to
total
expenses,
with
a
broader
group
of
actively-managed
ultrashort
bond
ETFs
(the
“Expense
Universe”),
the
information
for
which
was
derived
in
part
from
fund
financial
statements
available
to
Broadridge
as
of
the
date
of
its
analysis.
Nature,
Extent
and
Quality
of
Services
The
Board
considered
the
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
the
Sub-Adviser.
In
doing
so,
the
Trustees
relied
on
their
prior
experience
in
overseeing
the
management
of
the
fund
and
the
materials
provided
prior
to
and
at
the
INFORMATION
ABOUT
THE
REVIEW
AND
RENEWAL
OF
THE
FUND’S
MANAGEMENT
AND
SUB-INVESTMENT
ADVISORY
AGREEMENTS
(Unaudited)
(continued)
28
meeting.
The
Board
reviewed
the
Agreements
and
the
Adviser’s
and
the
Sub-Adviser’s
responsibilities
for
managing
investment
operations
of
the
fund
in
accordance
with
the
fund’s
investment
objective
and
policies,
and
applicable
legal
and
regulatory
requirements.
The
Board
appreciated
the
nature
of
the
fund
as
an
exchange-traded
fund
and
considered
the
background
and
experience
of
the
Adviser’s
and
the
Sub-
Adviser’s
senior
management,
including
those
individuals
responsible
for
portfolio
management
and
regulatory
compliance
of
the
funds.
The
Board
also
considered
the
portfolio
management
resources,
structures
and
practices
of
the
Adviser
and
the
Sub-Adviser,
including
those
associated
with
monitoring
and
ensuring
the
fund’s
compliance
with
its
investment
objective
and
policies
and
with
applicable
laws
and
regulations.
The
Board
further
considered
information
about
the
Sub-Adviser’s
best
execution
procedures
as
well
as
the
Adviser’s
and
the
Sub-Adviser’s
overall
investment
management
business.
The
Board
looked
at
the
Adviser’s
general
knowledge
of
the
investment
management
business
and
that
of
its
affiliates,
including
the
Sub-Adviser.
With
respect
to
the
Sub-Adviser,
the
Board
also
considered
the
Adviser’s
favorable
assessment
of
the
nature
and
quality
of
the
services
provided
by
the
Sub-Adviser.
Investment
Performance
The
Board
then
reviewed
the
results
of
the
fund’s
performance
comparisons
and
considered
that
the
fund's
total
return
performance
was
below
the
Performance
Group
and
Performance
Universe
medians
for
the
one-year
period.
The
Board
discussed
with
management
the
reasons
for
the
fund’s
underperformance,
noting
the
fund’s
performance
was
not
significantly
below
the
Performance
Group
and
Performance
Universe
medians
for
the
period.
Representatives
of
the
Adviser
noted
the
fund
is
managed
more
conservatively
than
certain
other
comparison
funds
and
discussed
the
effect
of
security
selection
on
the
Fund’s
relative
performance
during
the
period.
Representatives
of
the
Adviser
also
stated
that
the
usefulness
of
performance
comparisons
may
be
affected
by
a
number
of
factors,
including
different
investment
limitations
and
policies
that
may
be
applicable
to
the
fund
and
comparison
funds
and
the
end
date
selected.
Profits
Realized
by
the
Adviser
The
Board
considered
the
profitability
of
the
advisory
arrangement
with
the
fund
to
the
Adviser
and
its
affiliates.
The
Board
had
the
opportunity
to
discuss
with
representatives
of
the
Adviser
the
process
and
methodology
used
to
calculate
profitability.
Fees
Charged
to
Comparable
Funds
The
Board
evaluated
the
fund’s
unitary
fee
through
review
of
comparative
information
with
respect
to
fees
paid
by
similar
funds
-
i.e.,
other
actively-managed
ultrashort
bond
ETFs.
The
Board
explored
with
management
the
differences
between
the
fund’s
fee
29
and
fees
paid
by
similar
funds.
The
Board
noted
the
fund's
contractual
management
fee
was
lower
than
the
Expense
Group
median
and
the
fund's
total
expenses
were
lower
than
the
Expense
Group
median
and
the
Expense
Universe
median
total
expenses.
The
Board
considered
the
fee
paid
to
the
Sub-Adviser
in
relation
to
the
fee
paid
to
the
Adviser
by
the
fund
and
the
respective
services
provided
by
the
Sub-Adviser
and
the
Adviser.
The
Board
also
took
into
consideration
that
the
Sub-Adviser's
fee
is
paid
by
the
Adviser
and
not
the
fund.
Other
Benefits
The
Board
also
considered
whether
the
Adviser,
the
Sub-Adviser
or
their
affiliates
benefited
in
other
ways
from
their
relationship
with
the
funds,
noting
that
neither
the
Adviser
nor
the
Sub-Adviser
maintains
soft-dollar
arrangements
in
connection
with
the
fund’s
brokerage
transactions.
Economies
of
Scale
The
Board
reviewed
information
regarding
economies
of
scale
or
other
efficiencies
that
may
result
as
the
fund’s
assets
grow
in
size.
The
Board
noted
that
the
advisory
fee
rate
for
the
fund
did
not
provide
for
breakpoints
as
assets
of
the
fund
increases.
The
Adviser
asserted
that
one
of
the
benefits
of
the
unitary
fee
was
to
provide
an
unvarying
expense
structure,
which
could
be
lost
or
diluted
with
the
addition
of
breakpoints.
The
Board
noted
that
it
intends
to
continue
to
monitor
fees
as
the
fund
grows
in
size
and
assess
whether
fee
breakpoints
may
be
warranted.
Conclusion
After
weighing
the
foregoing
factors,
none
of
which
was
dispositive
in
itself
and
may
have
been
weighed
differently
by
each
Trustee,
the
Board
approved
the
continuation
of
the
Agreements
for
the
fund.
In
approving
the
continuance
of
the
Agreements,
the
Board
found
that
the
terms
of
the
Agreements
are
fair
and
reasonable
and
that
the
continuance
of
the
Agreements
are
in
the
best
interests
of
the
fund
and
its
shareholders.
BOARD
MEMBERS
INFORMATION
(Unaudited)
INDEPENDENT
BOARD
MEMBERS
30
J.
Charles
Cardona
(67)
Chairman
of
the
Board
(2020)
Principal
Occupation
During
Past
5
Years:
BNY Mellon
Family of Funds, 
Interested
Director 
(2014
2018), 
Independent Director 
(2019 – Present)
BNY
Mellon
Liquidity
Funds,
Director
(2004
Present)
and
Chairman
(2019
2021)
.
No.
of
Portfolios
for
which
Board
Member
Serves:
39,
including
22
managed
by
an
affiliate
of
the
Adviser
Kristen
M.
Dickey
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Independent
board
director
of
Marstone,
Inc.,
a
financial
technology
company
(since
2018);
Lead
non-executive
director
for
Aperture
Investors,
LLC,
an
investment
management
firm
(since
2018);
Managing
Director—Global
Head
of
Index
Strategy
at
BlackRock,
Inc.
(until
2017)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
F.
Jack
Liebau,
Jr.
(59)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
Director
at
Beach
Investment
Counsel,
a
financial
advisory
firm
(since
2020)
Corporate
director
(since
2015)
Other
Public
Company
Board
Memberships
During
Past
5
Years:
Myers
Industries,
an
industrial
company,
Director
(2015
Present;
Chairman
of
Board
2016
Present)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
Jill
I.
Mavro
(51)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
director
at
CapWGlobal,
LLC,
a
financial
technology
consulting
company
(since
2020)
Founder
and
Principal
of
Spoondrift
Advisory,
LLC
(since
2018);
Senior
Managing
Director,
Head
of
Strategic
Relationships
and
Member
of
SPDR
Executive
Committee
at
State
Street
Global
Advisors
(until
2018)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
31
Kevin
W.
Quinn
(64)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Partner
at
PricewaterhouseCoopers,
LLC
(until
2019)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
Stacy
L.
Schaus
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Chief
Executive
Officer
of
the
Schaus
Group
LLC,
a
consulting
firm
(since
2019);
Advisory
board
member
of
A&P
Capital,
a
consulting
firm
(from
2019-2021);
Executive
Vice
President—Defined
Contribution
Practice
Founder
at
PIMCO
Investment
Management
(until
2018).
No.
of
Portfolios
for
which
Board
Member
Serves:
17
OFFICERS
OF
THE
TRUST
(Unaudited)
32
DAVID
DIPETRILLO,
President
since
February
2020.
Vice
President
and
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2021;
Head
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
February
2023;
Head
of
North
America
Product,
BNY
Mellon
Investment
Management
from
January
2018
to
February
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
103
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
45
years
old
and
has
been
an
employee
of
BNY
Mellon
since
2005. 
PETER
M.
SULLIVAN,
Chief
Legal
Officer
since
July
2021,
Vice
President
and
Assistant
Secretary
since
February
2020.
Chief
Legal
Officer
of
BNY
Mellon
Investment
Adviser,
Inc.
and
Associate
General
Counsel
of
BNY
Mellon
since
July
2021;
Senior
Managing
Counsel
of
BNY
Mellon
from
December
2020
to
July
2021;
and
Managing
Counsel
of
BNY
Mellon
from
March
2009
to
December
2020.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
since
April
2004.
JAMES
WINDELS,
Treasurer
since
February
2020.
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2023;
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
September
2020;
and
Director
BNY
Mellon
Fund
Administration.
 He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
64
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1985.
SARAH
S.
KELLEHER,
Vice
President
and
Secretary
since
February
2020.
Vice
President
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
since
February
2020;
Senior
Managing
Counsel
of
BNY
Mellon
since
September
2021;
and
Managing
Counsel
of
BNY
Mellon
from
December
2017
to
September
2021. 
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
She
is
47
years
old
and
has
been
an
employee
of
BNY
Mellon
since
March
2013.
JAMES
BITETTO,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon
since
December
2019;
Managing
Counsel
of
BNY
Mellon
from
April
2014
to
December
2019;
and
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
December
1996.
DEIRDRE
CUNNANE,
Vice
President
and
Assistant
Secretary
since
February
2020.
Managing
Counsel
of
BNY
Mellon
since
December
2021;
Counsel
of
BNY
Mellon
from
August
2018
to
December
2021;
and
Senior
Regulatory
Specialist
at
BNY
Mellon
Investment
Management
Services
from
February
2016
to
August
2018.
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
32
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
August
2018.
JEFF
PRUSNOFSKY,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
58
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
October
1990.
AMANDA
QUINN,
Vice
President
and
Assistant
Secretary
since
February
2020.
Counsel
of
BNY
Mellon
since
June
2019;
Regulatory
Administration
Manager
at
BNY
Mellon
Investment
Management
Services from
September
2018
to
May
2019;
and
Senior
Regulatory
Specialist
at
BNY
Mellon
Investment
Management
Services
from
April
2015
to
August
2018.
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
33
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
June
2012.
JOANNE
SKERRETT,
Vice
President
and
Assistant
Secretary
since
March
2023.
Managing
Counsel
of
BNY
Mellon
since
June
2022;
and
Senior
Counsel
with
the
Mutual
Fund
Directors
Forum,
a
leading
funds
industry
organization,
from
2016
to
June
2022. 
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
51
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
2022.
DANIEL
GOLDSTEIN,
Vice
President
since
March
2022
Head
of
Product
Development
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023;
and
Senior
Vice
President,
Development
&
Oversight
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
103
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
the
Distributor
since
1991.
JOSEPH
MARTELLA,
Vice
President
since
March
2022
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
December
2022;
Head
of
Product
Management
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023,
and
Senior
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
103
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
46
years
old
and
has
been
an
employee
of
the
Distributor
since
1999.
GAVIN
C.
REILLY,
Assistant
Treasurer
since
February
2020.
Tax
Manager-BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
54
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1991.
ROBERT
SALVIOLO,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
1989.
ROBERT
SVAGNA,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
November
1990.
NATALYA
ZELENSKY,
Vice
President
and
Assistant
Secretary
since
February
2020
and
Chief
Compliance
Officer
since
August
2021.
Chief
Compliance
Officer
since
August
2021
and
Vice
President
since
February
2020
of
BNY
Mellon
ETF
Investment
Adviser,
LLC;
Managing
Counsel
of
BNY
Mellon
from
December
2019
to
August
2021;
Counsel
of
BNY
Mellon
from
May
2016
to
December
2019;
and
Assistant
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
from
April
2018
to
August
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
May
2016.
CARIDAD
M.
CAROSELLA,
Anti-Money
Laundering
Compliance
Officer
since
February
2020.
Anti-Money
Laundering
Compliance
Officer
of
the
BNY
Mellon
Family
of
Funds
and
BNY
Mellon
Funds
Trust.
She
is
an
officer
of
47
investment
companies
(comprised
of
116
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
54
years
old
and
OFFICERS
OF
THE
TRUST
(Unaudited)
(continued)
34
has
been
an
employee
of
the
Distributor
since
1997.
For
More
Information
2023
BNY
Mellon
Securities
Corporation
4862AR0623
Telephone
Call
your
financial
representative
or
1-833-ETF-BNYM
(383-2696)
(inside
the
U.S.
only)
Mail
BNY
Mellon
ETF
Trust,
240
Greenwich
Street,
New
York,
New
York
10286
E-Mail
Send
your
request
to
info@bnymellon.com
Internet
Information
can
be
viewed
online
or
downloaded
at
www.im.bnymellon.com
BNY
Mellon
ETF
Trust
discloses,
at
www.im.bnymellon.com
,
the
identities
and
quantities
of
the
securities
held
by
the
fund
daily.
The
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
SEC
)
for
the
first
and
third
quarters
of
the
fiscal
year
on
Form
N-PORT.
The
fund
s
Forms
N-PORT
are
available
on
the
SEC
s
website
at
www.sec.gov
.
Additionally,
the
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://im.bnymellon.com/etfliterature
.
The
fund
s
complete
schedule
of
portfolio
holdings,
as
filed
on
Form
N-PORT,
can
also
be
obtained
without
charge,
upon
request,
by
calling
1-833-383-2696.
A
description
of
the
policies
and
procedures
that
the
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
the
fund
voted
these
proxies
for
the
most
recent
12-month
period
ended
June
30
is
available
at
www.im.bnymellon.
com
and
on
the
SEC’s
website
at
www.sec.gov
.
The
description
of
the
policies
and
procedures
is
also
available
without
charge,
upon
request,
by
calling
1-833-383-2696.
BNY
Mellon
ETF
Trust
Custodian
BNY
Mellon
ETF
Investment
Adviser,
LLC
240
Greenwich
Street
New
York,
NY
10286
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Adviser
Transfer
Agent
&
Dividend
Disbursing
Agent
BNY
Mellon
ETF
Investment
Adviser,
LLC
201
Washington
Street
Boston,
MA
02108
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Sub-Adviser
Distributor
Dreyfus,
a
division
of
Mellon
Investments
Corporation
BNY
Mellon
Center
One
Boston
Place
Boston,
MA
02108
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
Ultra
Short
Income
ETF
BKUI
BNY
Mellon
ETF
Trust
ANNUAL
REPORT
June
30,
2023
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
Contents
The
Fund
Save
time.
Save
paper.
View
your
next
shareholder
report
online
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soon
as
it’s
available.
Log
into
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It’s
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few
minutes.
The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
Not
Bank-Guaranteed
May
Lose
Value
Discussion
of
Fund
Performance
3
Fund
Performance
6
Understanding
Your
Fund’s
Expenses
8
Statement
of
Investments
9
Statement
of
Assets
and
Liabilities
20
Statement
of
Operations
21
Statement
of
Changes
in
Net
Assets
22
Financial
Highlights
23
Notes
to
Financial
Statements
24
Report
of
Independent
Registered
Public
Accounting
Firm
37
Important
Tax
Information
38
Information
About
the
Review
and
Renewal
of
the
Fund’s
Management
and
Sub-Investment
Advisory
Agreements
39
Board
Members
Information
42
Officers
of
the
Trust
44
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
12-month
period
from
July
1,
2022,
through
June
30,
2023,
as
provided
by
Portfolio
Managers,
Erin
Spalsbury,
CFA
and
Jonathan
William
Earle,
CFA,
of
Insight
North
America
LLC,
sub-adviser.
Market
and
Fund
Performance
Overview
For
the
12-month
period
ended
June
30,
2023,
the
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
2.01%.
1
In
comparison,
the
ICE
BofA
U.S.
Corporate
Index
(the
“Index”)
achieved
a
total
return
of
1.68%
for
the
same
period.
2
Fixed-income
markets
produced
positive
returns
over
the
reporting
period
in
an
environment
of
tightening
monetary
conditions
and
declining
inflation.
Because
the
fund
cannot
hold
all
of
the
securities
in
the
Index,
the
difference
in
returns
between
the
fund
and
the
Index
is
due
primarily
to
active
management
decisions.
The
Fund’s
Investment
Approach
To
pursue
its
goal,
the
fund
normally
invests
at
least
80%
of
its
net
assets,
plus
the
amount
of
any
borrowings
for
investment
purposes,
in
corporate
debt
securities
issued
by
companies
that
demonstrate
attractive
investment
attributes
and
attractive
business
practices
based
on
an
environmental,
social
and
governance
(ESG)
evaluation
methodology.
The
fund’s
investment
in
corporate
debt
securities
principally
includes
corporate
bonds,
notes
and
debentures
of
U.S.
and
non-U.S.
issuers,
including
the
securities
of
issuers
in
emerging-markets
countries.
The
fund
may,
from
time
to
time,
invest
a
significant
portion
(more
than
20%)
of
its
total
assets
in
securities
of
companies
in
certain
sectors
or
located
in
particular
countries
or
regions.
The
fund
currently
expects
to
invest
a
significant
portion
of
its
assets
in
securities
of
companies
located
in
the
broader
European
region.
Market
Aided
by
Easing
Inflation
Markets
were
affected
largely
by
monetary
tightening
by
central
banks
and
by
declining
inflation.
The
Federal
Reserve
(the
“Fed”)
increased
the
federal
funds
rate
350
basis
points
(bps)
over
the
reporting
period,
tightening
credit
conditions
and
bringing
down
inflation. 
The
pace
of
monetary
tightening
had
slowed
late
in
2022
and
early
2023
as
there
were
signs,
in
some
countries
more
than
others,
that
inflationary
pressures
were
beginning
to
subside.
U.S.
inflation
continued
its
trend
lower
from
its
peak
in
2022.
With
inflation
falling,
the
Fed
paused
its
rate-hiking
program
in
June
2023
to
assess
the
impacts. 
The
Fed’s
tightening
affected
financial
markets.
Treasury
yields
rose
significantly,
up
112
bps
on
the
five-year
bond,
82
bps
on
the
10
year
bond
and
68
bps
on
the
30
year
bond.
In
the
stock
market,
the
S&P
500
gained
19.5%
during
the
period,
though
16.9%
has
been
in
the
first
half
of
2023.
The
index
fell
20.2%
in
the
first
half
of
2022.
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
In
the
investment-grade
market,
credit
spreads
tightened
32
bps
over
the
period,
though
absolute
returns
were
negative,
and
spread
performance
over
the
period
was
volatile,
impacted
by
the
crisis
in
British
gilts
late
in
2022
and
the
regional
banking
crisis
in
March
2023.
Both
events
resulted
in
spikes
in
spreads,
but
markets
rebounded
quickly
as
central
banks
stepped
in
to
ensure
proper
market
functioning. 
Fundamentals
generally
remained
stable
in
the
investment-grade
market,
supported
by
continued
strength
in
earnings,
including
an
uptick
in
positive
earnings
surprises.
The
second
quarter
of
2023
was
dominated
by
the
primary
market,
which
was
robust,
as
many
corporates
issued
debt
to
finance
mergers
and
acquisitions.
The
high
yield
market
tightened
significantly,
with
spreads
tightening
by
179
bps,
from
569
bps
to
390
bps,
as
many
names
received
credit
rating
upgrades,
and
few
needed
to
borrow.
One-year
returns
in
the
high
yield
market
were
positive
and
all-in
yields
remained
attractive
at
more
than
8.5%.
While
flows
into
investment-grade
credit
were
negative
for
2022
and
turned
positive
in
2023,
flows
into
high
yield
were
mixed. 
Security
Selection
Aided
Performance
Security
selection
was
a
strong
contributor
to
the
fund’s
outperformance.
Sector
selection
was
strong
in
consumer
sectors,
capital
goods
and
REITs,
though
somewhat
poorer
in
the
banking
sector.
Leading
contributors
included
Italian
power
company
ENEL
Finance
America
LLC,
multinational
brewer
Anheuser-Busch
InBev
Worldwide,
Inc.,
Dutch
investment
firm
Prosus
,
and
Bank
of
America
Corp.
Exposure
to
credit
also
made
a
modest
contribution
as
spreads
rebounded
in
early
2023.
Duration
contributed
20
bps
to
performance
as
well,
as
periodic
short-duration
positioning
proved
favorable
when
the
Fed
repeatedly
raised
the
federal
funds
rate.
On
the
other
hand,
yield
curve
positioning
detracted
from
performance.
The
fund
was
overweight
in
the
short-to-intermediate
part
of
the
yield
curve
(less
than
10
years)
as
the
yield
curve
flattened
when
shorter
rates
rose
more
than
longer
rates.
Sector
selection
also
detracted,
with
our
overweight
to
the
banking
sector
and
REITs
and
our
underweight
to
foreign
agencies
hampering
returns.
This
was
partially
offset
by
overweight
to
the
automobile
sector
and
underweight
to
the
electric
utilities
sectors.
A
portion
of
the
positive
selection
effect
was
offset
somewhat
by
underperformance
from
Credit
Suisse
and
Citizens
Financial
Group,
Inc.
A
lack
of
exposure
to
gaming
companies,
such
as
Macau-based
Sands
China
,
a
subsidiary
of
Las
Vegas
Sands,
also
detracted.
These
rebounded
as
China’s
economy
reopened
in
the
wake
of
the
pandemic.
5
Rate
Hikes
Likely
Near
an
End
Despite
some
positive
economic
data,
the
risks
of
a
global
recession
remain.
Labor
markets
remain
robust,
particularly
in
services
sectors,
but
personal
savings
have
declined
due
to
higher
prices
and
increasing
rents
(though
savings
started
at
extraordinarily
high
levels). 
An
interest-rate
hike
is
expected
in
July
2023,
and
another
may
occur
in
September
2023,
but
the
Fed
is
likely
near
the
end
of
its
hiking
cycle,
and
we
do
not
expect
to
see
a
recession
in
2023.
We
do
recognize,
however,
that
recession
is
more
likely
in
the
first
half
of
2024.
We
continue
to
expect
spreads
on
investment-grade
credit
to
be
in
a
range
of
130
bps
to
170
bps
for
the
remainder
of
the
year,
given
that
strong
technical
factors
are
likely
to
keep
them
near
the
tight
end
of
the
range.
With
marginally
deteriorating
fundamentals,
spreads
could
widen
in
the
back
half
of
the
year,
however.
July
17,
2023
1
Total
return
includes
reinvestment
of
dividends
and
any
capital
gains
paid.
A
fund’s
net
asset
value
(NAV)
is
the
sum
of
all
its
assets
less
any
liabilities,
divided
by
the
number
of
shares
outstanding.
ETFs
are
bought
and
sold
at
market
prices,
not
NAV,
therefore
an
investor’s
return
at
market
price
may
differ
from
NAV.
Past
performance
is
no
guarantee
of
future
results.
Share
price,
yield
and
investment
return
fluctuate
such
that
upon
redemption,
fund
shares
may
be
worth
more
or
less
than
their
original
cost.
2
Source:
Lipper
Inc.
ICE
BofA
U.S.
Corporate
Index
is
an
unmanaged
index
comprised
of
U.S.
dollar
denominated
investment
grade,
fixed
rate
corporate
debt
securities
publicly
issued
in
the
U.S.
domestic
market
with
at
least
$250
million
outstanding.
Investors
cannot
invest
directly
in
any
index.
Bonds
are
subject
generally
to
interest-rate,
credit,
liquidity
and
market
risks,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
Generally,
all
other
factors
being
equal,
bond
prices
are
inversely
related
to
interest-rate
changes,
and
rate
increases
can
cause
price
declines.
ETFs
trade
like
stocks,
are
subject
to
investment
risk,
including
possible
loss
of
principal.
ETF
shares
are
listed
on
an
exchange,
and
shares
are
generally
purchased
and
sold
in
the
secondary
market
at
market
price.
At
times,
the
market
price
may
be
at
a
premium
or
discount
to
the
ETF’s
per
share
NAV.
In
addition,
ETFs
are
subject
to
the
risk
that
an
active
trading
market
for
an
ETF’s
shares
may
not
develop
or
be
maintained.
Buying
or
selling
ETF
shares
on
an
exchange
may
require
payment
of
brokerage
commissions.
The
fund’s
incorporation
of
ESG
considerations
into
its
investment
approach
may
cause
it
to
make
different
investments
than
funds
that
invest
principally
in
corporate
bonds
but
do
not
incorporate
ESG
considerations
when
selecting
investments.
Under
certain
economic
conditions,
this
could
cause
the
fund
to
underperform
funds
that
do
not
incorporate
ESG
considerations.
The
fund
may,
but
is
not
required
to,
use
derivative
instruments.
A
small
investment
in
derivatives
could
have
a
potentially
large
impact
on
the
fund’s
performance.
The
use
of
derivatives
involves
risks
different
from,
or
possibly
greater
than,
the
risks
associated
with
investing
directly
in
the
underlying
assets,
and
the
fund's
use
of
derivatives
may
result
in
losses
to
the
fund
and
increased
portfolio
volatility.
Please
note:
the
position
in
any
security
highlighted
with
italicized
typeface
was
sold
during
the
reporting
period.
FUND
PERFORMANCE
(Unaudited)
6
Comparison
of
change
in
value
of
a
$10,000
investment
in
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
with
a
hypothetical
investment
of
$10,000
in
the
ICE
BofA
U.S.
Corporate
Index
(the
“Index”).
Source:
FactSet
Past
performance
is
not
predictive
of
future
performance.
The
above
graph
compares
a
hypothetical
$10,000
investment
made
in
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
on
3/21/22
to
a
hypothetical
investment
of
$10,000
made
in
the
Index
on
that
date
using
closing
market
price
return.
All
dividends
and
capital
gain
distributions
are
reinvested.
The
fund’s
performance
shown
in
the
line
graph
above
takes
into
account
all
applicable
fees
and
expenses.
The
Index
is
a
float
adjusted
market
capitalization
weighted
index
that
is
designed
to
measure
the
performance
of
U.S.
large-capitalization
stocks.
The
Index’s
initial
universe
of
eligible
securities
includes
common
stocks,
tracking
stock
and
shares
of
real
estate
investment
trusts
(REITs)
issued
by
U.S.
companies
and
traded
on
the
New
York
Stock
Exchange,
NASDAQ,
or
NYSE
Market
LLC.
At
each
reconstitution,
the
initial
universe
is
screened
to
exclude
securities
based
on
the
number
of
non-trading
days
in
the
preceding
quarter
and
trading
volume
during
the
preceding
six-month
period.
Securities
with
more
than
10
non-trading
days
in
the
preceding
quarter,
or
that
have
a
bottom
25%
liquidity
score
as
ranked
by
the
index
provider
based
on
the
preceding
six-
month
trading
volume,
are
excluded.
The
remaining
securities
comprise
the
investable
universe.
The
Index
is
composed
of
the
6
securities
of
companies
whose
cumulative
total
market
capitalization
represents
approximately
the
top
70%
of
the
remaining
securities
comprising
the
investable
universe.
Investors
cannot
invest
directly
in
any
index.
Further
information
relating
to
fund
performance,
including
expense
reimbursements,
if
applicable,
is
contained
in
the
Financial
Highlight
section
of
the
prospectus
and
elsewhere
in
this
report.
The
performance
data
quoted
represents
past
performance,
which
is
no
guarantee
of
future
results.
Share
price
and
investment
return
fluctuate
and
an
investor’s
shares
may
be
worth
more
or
less
than
Average
Annual
Total
Returns
as
of
June
30,
2023
Inception
Date
1
Year
From
Inception
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
Net
Asset
Value
Return
3/21/22
2.01%
(5.06)%
Market
Price
Return
3/21/22
1.69%
(4.86)%
ICE
BofA
U.S.
Corporate
Index
3/21/22
1.68%
(4.33)%
7
original
cost
upon
redemption.
Current
performance
may
be
lower
or
higher
than
the
performance
quoted.
Go
to
www.
im.bnymellon.com
for
the
fund’s
most
recent
month-end
returns.
The
fund’s
performance
shown
in
the
graph
and
table
does
not
reflect
the
deduction
of
taxes
that
a
shareholder
would
pay
on
fund
distributions
or
the
redemption
of
fund
shares.
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
8
As
a
shareholder
of
the
fund,
you
pay
ongoing
expenses,
such
as
management
fees
and
other
expenses.
Using
the
information
below,
you
can
estimate
how
these
expenses
affect
your
investment
and
compare
them
with
the
expenses
of
other
funds.
For
more
information,
see
your
fund’s
prospectus
or
talk
to
your
financial
adviser.
Actual
Expenses
The
information
under
each
column
in
the
table
below
entitled
“Actual”
provides
information
about
on
how
much
a
$1,000
investment
would
be
worth
at
the
close
of
the
period,
assuming
net
asset
value
total
returns
and
actual
expenses.
You
may
use
the
information
in
these
columns,
together
with
the
amount
you
invested,
to
estimate
the
expenses
that
you
paid
over
the
period.
Simply
divide
your
account
value
by
$1,000
(for
example,
an
$8,600
account
value
divided
by
$1,000
=
8.6),
then
multiply
the
result
by
the
number
for
the
fund
under
the
heading
entitled
“Expenses
paid
for
the
period”
to
estimate
the
expenses
you
paid
on
your
account
during
this
period.
Hypothetical
Example
For
Comparison
Purposes
The
Securities
and
Exchange
Commission
(“SEC”)
has
established
guidelines
to
help
investors
assess
fund
expenses.
The
information
under
each
column
in
the
table
entitled
“Hypothetical”
provides
information
about
hypothetical
account
values
and
hypothetical
expenses
based
on
the
fund’s
actual
expense
ratio
and
an
assumed
rate
of
return
of
5%
per
year
before
expenses,
which
is
not
the
fund’s
actual
return.
The
hypothetical
account
values
and
expenses
may
not
be
used
to
estimate
the
actual
ending
account
balance
or
expenses
you
paid
for
the
period.
You
may
use
this
information
to
compare
the
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
To
do
so,
compare
this
5%
hypothetical
example
with
the
5%
hypothetical
examples
that
appear
in
the
shareholder
reports
of
the
other
funds.
Please
note
that
the
expenses
shown
in
the
table
are
meant
to
highlight
your
ongoing
costs
only
and
do
not
reflect
any
transactional
costs,
such
as
brokerage
commissions
paid
on
purchases
and
sales
of
fund
shares.
Therefore,
the
ending
account
values
and
expenses
paid
for
the
period
in
the
table
are
useful
in
comparing
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
In
addition,
if
these
transactional
costs
were
included,
your
costs
would
have
been
higher.
For
the
six
months
ended
June
30,
2023
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
six-month
period
ended
June
30,
2023.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
181/365.
Beginning
account
value
($)
Ending
account
value($)
Expense
paid
for
the
period
($)
Annualized
expense
ratios
for
the
period
(%)
Actual
Hypothetical
Actual
Hypothetical
Actual
(a)
Hypothetical
(a)
1,000.00
1,000.00
1,034.10
1,023.06
1.77
1.76
0.35
STATEMENT
OF
INVESTMENTS
June
30,
2023
9
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
Airlines
0.3%
Delta
Air
Lines,
Inc.
/
SkyMiles
IP
Ltd.,
4.75%,
10/20/2028
(a)
80,000
77,720
77,720
Auto
Manufacturers
2.9%
Ford
Motor
Co.
3.25%,
2/12/2032
75,000
59,070
6.10%,
8/19/2032
35,000
33,955
General
Motors
Co.
5.60%,
10/15/2032
(b)
142,000
137,448
5.95%,
4/01/2049
140,000
130,912
Mercedes-Benz
Finance
North
America
LLC,
1.45%,
3/02/2026
(a)
150,000
136,217
Stellantis
Finance
US,
Inc.,
2.69%,
9/15/2031
(a)
200,000
159,915
657,517
Banks
22.1%
Bank
of
America
Corp.
3.82%,
1/20/2028
165,000
156,122
5.20%,
4/25/2029
113,000
111,836
3.19%,
7/23/2030
200,000
176,448
2.57%,
10/20/2032
134,000
109,195
5.29%,
4/25/2034
65,000
64,425
Bank
of
Nova
Scotia
(The),
4.85%,
2/01/2030
108,000
104,304
Canadian
Imperial
Bank
of
Commerce,
5.00%,
4/28/2028
100,000
98,460
Citigroup,
Inc.
3.11%,
4/08/2026
125,000
119,410
3.98%,
3/20/2030
195,000
180,468
6.17%,
5/25/2034
54,000
54,500
Citizens
Financial
Group,
Inc.,
5.64%,
5/21/2037
80,000
68,963
Cooperatieve
Rabobank
UA,
1.00%,
9/24/2026
(a)
250,000
223,457
Deutsche
Bank
AG,
7.08%,
2/10/2034
200,000
185,091
Goldman
Sachs
Group,
Inc.
(The)
1.09%,
12/09/2026
150,000
133,748
2.64%,
2/24/2028
60,000
54,487
4.41%,
4/23/2039
220,000
192,174
HSBC
Holdings
PLC,
6.33%,
3/09/2044
200,000
207,520
JPMorgan
Chase
&
Co.
0.77%,
8/09/2025
300,000
282,662
3.88%,
7/24/2038
170,000
146,866
3.11%,
4/22/2051
100,000
69,984
Morgan
Stanley
3.88%,
1/27/2026
250,000
241,414
4.68%,
7/17/2026
130,000
127,623
1.93%,
4/28/2032
250,000
195,276
5.95%,
1/19/2038
38,000
37,529
NatWest
Group
PLC,
7.47%,
11/10/2026
200,000
204,670
Nordea
Bank
Abp,
5.38%,
9/22/2027
(a)
200,000
197,599
STATEMENT
OF
INVESTMENTS
(continued)
10
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Banks
22.1%
(continued)
PNC
Financial
Services
Group,
Inc.
(The)
4.76%,
1/26/2027
250,000
244,453
4.63%,
6/06/2033
95,000
87,452
Societe
Generale
SA,
6.22%,
6/15/2033
(a)
200,000
186,358
Sumitomo
Mitsui
Financial
Group,
Inc.,
2.35%,
1/15/2025
200,000
189,736
Truist
Financial
Corp.
6.05%,
6/08/2027
14,000
14,012
5.87%,
6/08/2034
10,000
10,009
UBS
Group
AG
2.59%,
9/11/2025
(a)
250,000
238,396
1.49%,
8/10/2027
(a)
200,000
171,903
US
Bancorp,
5.78%,
6/12/2029
86,000
86,032
Westpac
Banking
Corp.,
2.67%,
11/15/2035
50,000
38,409
5,010,991
Beverages
1.2%
Anheuser-Busch
Cos.
LLC
/
Anheuser-Busch
InBev
Worldwide,
Inc.,
4.90%,
2/01/2046
100,000
95,663
Anheuser-Busch
InBev
Worldwide,
Inc.
4.60%,
4/15/2048
73,000
67,831
5.55%,
1/23/2049
100,000
105,496
268,990
Biotechnology
1.5%
Amgen,
Inc.
1.65%,
8/15/2028
75,000
64,189
5.25%,
3/02/2030
33,000
33,091
5.60%,
3/02/2043
33,000
33,123
4.66%,
6/15/2051
100,000
89,644
4.88%,
3/01/2053
22,000
20,257
5.65%,
3/02/2053
31,000
31,416
Illumina,
Inc.,
5.75%,
12/13/2027
68,000
68,341
340,061
Building
Materials
1.4%
Builders
FirstSource,
Inc.,
6.38%,
6/15/2032
(a)
28,000
27,849
Carrier
Global
Corp.,
2.72%,
2/15/2030
150,000
129,232
Johnson
Controls
International
PLC
/
Tyco
Fire
&
Security
Finance
SCA,
4.90%,
12/01/2032
94,000
93,196
Trane
Technologies
Financing
Ltd.,
5.25%,
3/03/2033
60,000
60,770
311,047
Chemicals
2.7%
Braskem
Netherlands
Finance
BV,
4.50%,
1/31/2030
(a)
200,000
171,963
Dow
Chemical
Co.
(The),
6.30%,
3/15/2033
(b)
33,000
35,516
Nutrien
Ltd.
4.00%,
12/15/2026
200,000
192,126
4.90%,
3/27/2028
12,000
11,779
11
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Chemicals
2.7%
(continued)
Sherwin-Williams
Co.
(The),
3.45%,
6/01/2027
200,000
188,617
600,001
Commercial
Services
1.7%
Ashtead
Capital,
Inc.,
4.25%,
11/01/2029
(a)
200,000
181,689
ERAC
USA
Finance
LLC
3.80%,
11/01/2025
(a)
125,000
119,628
4.90%,
5/01/2033
(a)
77,000
75,304
376,621
Computers
4.3%
Apple,
Inc.
2.20%,
9/11/2029
100,000
87,803
4.65%,
2/23/2046
100,000
98,722
3.95%,
8/08/2052
25,000
22,052
4.10%,
8/08/2062
33,000
28,918
Dell
International
LLC
/
EMC
Corp.
3.38%,
12/15/2041
(a)
80,000
56,485
3.45%,
12/15/2051
(a)
70,000
47,012
Hewlett
Packard
Enterprise
Co.,
1.45%,
4/01/2024
125,000
121,023
HP,
Inc.,
1.45%,
6/17/2026
130,000
116,706
International
Business
Machines
Corp.,
1.95%,
5/15/2030
160,000
132,640
Kyndryl
Holdings,
Inc.
3.15%,
10/15/2031
40,000
30,036
4.10%,
10/15/2041
40,000
26,758
Lenovo
Group
Ltd.,
6.54%,
7/27/2032
(a)
200,000
201,915
970,070
Diversified
Financial
Services
4.0%
AerCap
Ireland
Capital
DAC
/
AerCap
Global
Aviation
Trust,
3.85%,
10/29/2041
150,000
114,077
Ally
Financial,
Inc.
3.88%,
5/21/2024
100,000
97,705
8.00%,
11/01/2031
100,000
103,896
Capital
One
Financial
Corp.,
2.36%,
7/29/2032
79,000
55,832
Discover
Financial
Services,
6.70%,
11/29/2032
89,000
91,725
Intercontinental
Exchange,
Inc.
4.60%,
3/15/2033
80,000
77,687
4.95%,
6/15/2052
24,000
22,854
LSEGA
Financing
PLC,
1.38%,
4/06/2026
(a)
200,000
178,460
NASDAQ,
Inc.,
5.95%,
8/15/2053
27,000
27,665
Synchrony
Financial,
4.38%,
3/19/2024
150,000
147,108
917,009
Electric
5.4%
Avangrid,
Inc.,
3.20%,
4/15/2025
130,000
123,682
STATEMENT
OF
INVESTMENTS
(continued)
12
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Electric
5.4%
(continued)
Consolidated
Edison
Co.
of
New
York,
Inc.
Series
05-A,
5.30%,
3/01/2035
135,000
133,523
Series
A,
4.13%,
5/15/2049
100,000
82,147
Electricite
de
France
SA,
9.13%
(a)(c)
200,000
205,596
ENEL
Finance
America
LLC,
7.10%,
10/14/2027
(a)
200,000
210,298
ENEL
Finance
International
NV,
5.00%,
6/15/2032
(a)
200,000
189,218
Eversource
Energy,
Series
R,
1.65%,
8/15/2030
110,000
87,314
New
England
Power
Co.,
5.94%,
11/25/2052
(a)
71,000
74,307
Public
Service
Electric
&
Gas
Co.
4.65%,
3/15/2033
80,000
78,564
5.13%,
3/15/2053
44,000
44,426
1,229,075
Entertainment
1.1%
Warnermedia
Holdings,
Inc.
3.64%,
3/15/2025
150,000
144,760
5.14%,
3/15/2052
67,000
54,599
5.39%,
3/15/2062
50,000
40,782
240,141
Environmental
Control
0.5%
Waste
Management,
Inc.,
4.63%,
2/15/2030
115,000
113,397
113,397
Food
2.4%
General
Mills,
Inc.,
4.95%,
3/29/2033
134,000
132,862
JM
Smucker
Co.
(The),
4.25%,
3/15/2035
50,000
45,424
Kraft
Heinz
Foods
Co.
3.88%,
5/15/2027
100,000
96,067
5.20%,
7/15/2045
55,000
52,407
5.50%,
6/01/2050
56,000
55,592
SYSCO
Corp.,
2.40%,
2/15/2030
175,000
149,193
531,545
Forest
Products
&
Paper
0.4%
Suzano
Austria
GmbH,
3.75%,
1/15/2031
100,000
85,417
85,417
Gas
0.2%
Atmos
Energy
Corp.,
5.50%,
6/15/2041
55,000
55,168
55,168
Healthcare-Products
2.4%
Alcon
Finance
Corp.,
5.38%,
12/06/2032
(a)
200,000
202,803
Medtronic
Global
Holdings
SCA,
1.75%,
7/02/2049
100,000
69,541
Thermo
Fisher
Scientific,
Inc.,
1.50%,
10/01/2039
100,000
76,762
Zimmer
Biomet
Holdings,
Inc.,
1.45%,
11/22/2024
200,000
188,430
537,536
13
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Healthcare-Services
2.4%
HCA,
Inc.
5.25%,
6/15/2026
150,000
148,413
4.63%,
3/15/2052
(a)
55,000
45,245
Roche
Holdings,
Inc.,
2.08%,
12/13/2031
(a)
200,000
164,892
UnitedHealth
Group,
Inc.
5.15%,
10/15/2025
43,000
43,134
3.05%,
5/15/2041
50,000
38,692
5.88%,
2/15/2053
25,000
27,795
4.95%,
5/15/2062
29,000
27,922
6.05%,
2/15/2063
42,000
47,537
543,630
Home
Builders
0.3%
KB
Home,
4.00%,
6/15/2031
28,000
24,175
PulteGroup,
Inc.,
5.50%,
3/01/2026
50,000
49,743
73,918
Insurance
3.4%
Allstate
Corp.
(The),
3.85%,
8/10/2049
50,000
38,910
Jackson
Financial,
Inc.,
1.13%,
11/22/2023
250,000
245,464
Liberty
Mutual
Group,
Inc.,
4.30%,
2/01/2061
(a)
54,000
34,123
Marsh
&
McLennan
Cos.,
Inc.,
5.45%,
3/15/2053
50,000
50,953
MetLife,
Inc.
6.40%,
12/15/2036
100,000
99,931
5.00%,
7/15/2052
8,000
7,527
Metropolitan
Life
Global
Funding
I,
1.55%,
1/07/2031
(a)
150,000
116,831
Principal
Life
Global
Funding
II,
0.88%,
1/12/2026
(a)
200,000
177,949
771,688
Internet
0.3%
Amazon.com,
Inc.,
2.88%,
5/12/2041
100,000
77,202
77,202
Lodging
0.5%
Marriott
International,
Inc.
5.00%,
10/15/2027
38,000
37,724
Series
HH,
2.85%,
4/15/2031
90,000
75,728
113,452
Media
2.9%
Charter
Communications
Operating
LLC
/
Charter
Communications
Operating
Capital
Corp.
6.48%,
10/23/2045
60,000
56,447
4.40%,
12/01/2061
50,000
33,794
Comcast
Corp.
4.15%,
10/15/2028
55,000
53,317
4.65%,
2/15/2033
225,000
223,465
2.94%,
11/01/2056
150,000
97,789
STATEMENT
OF
INVESTMENTS
(continued)
14
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Media
2.9%
(continued)
Walt
Disney
Co.
(The)
3.35%,
3/24/2025
150,000
145,423
3.50%,
5/13/2040
68,000
56,281
666,516
Mining
0.2%
Newmont
Corp.,
2.80%,
10/01/2029
60,000
51,641
51,641
Miscellaneous
Manufacturing
0.6%
Eaton
Corp.
4.15%,
3/15/2033
119,000
113,101
4.70%,
8/23/2052
13,000
12,479
125,580
Oil
&
Gas
3.9%
AKER
BP
ASA
5.60%,
6/13/2028
(a)
300,000
298,026
3.10%,
7/15/2031
(a)
200,000
165,635
BP
Capital
Markets
America,
Inc.
3.54%,
4/06/2027
200,000
191,076
3.00%,
2/24/2050
65,000
45,367
Ecopetrol
SA,
8.88%,
1/13/2033
25,000
24,777
Parkland
Corp.,
4.50%,
10/01/2029
(a)
50,000
43,425
TotalEnergies
Capital
International
SA,
3.13%,
5/29/2050
90,000
65,460
TotalEnergies
Capital
SA,
3.88%,
10/11/2028
60,000
57,557
891,323
Oil
&
Gas
Services
0.8%
Schlumberger
Holdings
Corp.,
4.30%,
5/01/2029
(a)
200,000
190,634
190,634
Packaging
&
Containers
0.1%
Ball
Corp.,
6.00%,
6/15/2029
(b)
27,000
26,831
26,831
Pharmaceuticals
6.6%
AbbVie,
Inc.
2.60%,
11/21/2024
250,000
239,988
4.05%,
11/21/2039
150,000
130,674
4.25%,
11/21/2049
35,000
30,232
AstraZeneca
Finance
LLC,
2.25%,
5/28/2031
150,000
126,645
CVS
Health
Corp.
5.13%,
2/21/2030
115,000
114,277
5.25%,
1/30/2031
23,000
22,935
5.63%,
2/21/2053
60,000
59,691
5.88%,
6/01/2053
8,000
8,210
ELI
Lilly
&
Co.,
4.70%,
2/27/2033
45,000
45,607
15
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Pharmaceuticals
6.6%
(continued)
Merck
&
Co.,
Inc.
4.90%,
5/17/2044
48,000
48,155
2.75%,
12/10/2051
50,000
34,541
5.15%,
5/17/2063
14,000
14,312
Pfizer
Investment
Enterprises
Pte
Ltd.
5.30%,
5/19/2053
46,000
47,862
5.34%,
5/19/2063
72,000
72,920
Pfizer,
Inc.,
2.63%,
4/01/2030
240,000
213,498
Shire
Acquisitions
Investments
Ireland
DAC,
3.20%,
9/23/2026
100,000
93,932
Takeda
Pharmaceutical
Co.
Ltd.,
5.00%,
11/26/2028
200,000
198,928
1,502,407
Pipelines
2.4%
Enbridge,
Inc.
0.55%,
10/04/2023
150,000
148,093
5.50%,
7/15/2077
60,000
53,511
Galaxy
Pipeline
Assets
Bidco
Ltd.,
2.16%,
3/31/2034
(a)
177,420
151,081
ONEOK,
Inc.,
7.15%,
1/15/2051
100,000
104,767
Williams
Cos.,
Inc.
(The),
5.75%,
6/24/2044
80,000
78,060
535,512
Real
Estate
5.3%
Alexandria
Real
Estate
Equities,
Inc.,
1.88%,
2/01/2033
167,000
122,233
American
Homes
4
Rent
LP
2.38%,
7/15/2031
100,000
79,552
4.30%,
4/15/2052
34,000
26,579
Boston
Properties
LP,
2.75%,
10/01/2026
100,000
88,373
Crown
Castle,
Inc.,
1.05%,
7/15/2026
127,000
111,279
Equinix,
Inc.,
1.00%,
9/15/2025
(b)
100,000
90,343
Extra
Space
Storage
LP
3.90%,
4/01/2029
16,000
14,597
2.35%,
3/15/2032
65,000
50,875
Iron
Mountain
Information
Management
Services,
Inc.,
5.00%,
7/15/2032
(a)
50,000
43,236
ProLogis
Euro
Finance
LLC,
1.50%,
9/10/2049
100,000
59,733
Public
Storage,
1.95%,
11/09/2028
125,000
107,320
Rexford
Industrial
Realty
LP,
5.00%,
6/15/2028
135,000
131,256
Simon
Property
Group
LP
1.75%,
2/01/2028
100,000
85,614
3.25%,
9/13/2049
75,000
50,489
WP
Carey,
Inc.,
3.85%,
7/15/2029
160,000
145,436
1,206,915
Retail
1.9%
7-Eleven,
Inc.,
2.50%,
2/10/2041
(a)
100,000
67,012
Home
Depot,
Inc.
(The),
3.50%,
9/15/2056
150,000
115,531
STATEMENT
OF
INVESTMENTS
(continued)
16
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Retail
1.9%
(continued)
Lowe's
Cos.,
Inc.
1.70%,
9/15/2028
50,000
42,408
2.80%,
9/15/2041
100,000
70,803
4.25%,
4/01/2052
6,000
4,901
5.63%,
4/15/2053
47,000
47,009
4.45%,
4/01/2062
37,000
29,745
Macy's
Retail
Holdings
LLC,
5.88%,
3/15/2030
(a)
67,000
59,777
437,186
Semiconductors
1.7%
Advanced
Micro
Devices,
Inc.,
4.39%,
6/01/2052
46,000
41,927
Intel
Corp.
5.20%,
2/10/2033
37,000
37,370
5.63%,
2/10/2043
30,000
30,487
5.70%,
2/10/2053
12,000
12,216
KLA
Corp.,
5.25%,
7/15/2062
41,000
41,544
Micron
Technology,
Inc.,
5.88%,
9/15/2033
72,000
71,385
NXP
BV
/
NXP
Funding
LLC
/
NXP
USA,
Inc.,
3.25%,
5/11/2041
120,000
87,446
Qualcomm,
Inc.,
1.65%,
5/20/2032
50,000
39,489
Texas
Instruments,
Inc.,
5.05%,
5/18/2063
31,000
31,088
392,952
Software
3.1%
Fidelity
National
Information
Services,
Inc.,
1.15%,
3/01/2026
130,000
116,032
Microsoft
Corp.
2.70%,
2/12/2025
200,000
192,974
2.68%,
6/01/2060
100,000
67,152
Oracle
Corp.
4.65%,
5/06/2030
49,000
47,374
3.65%,
3/25/2041
100,000
77,108
4.00%,
7/15/2046
50,000
38,463
5.55%,
2/06/2053
48,000
46,515
VMware,
Inc.,
1.40%,
8/15/2026
130,000
114,859
700,477
Telecommunications
3.6%
AT&T,
Inc.
2.30%,
6/01/2027
100,000
89,984
2.55%,
12/01/2033
200,000
157,164
3.50%,
6/01/2041
100,000
76,865
3.55%,
9/15/2055
50,000
35,040
Rogers
Communications,
Inc.
4.50%,
3/15/2042
(a)
80,000
66,482
4.55%,
3/15/2052
(a)
62,000
49,905
T-Mobile
USA,
Inc.,
3.50%,
4/15/2031
150,000
132,507
17
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
97.7%
(continued)
Telecommunications
3.6%
(continued)
Verizon
Communications,
Inc.
1.50%,
9/18/2030
100,000
79,086
2.85%,
9/03/2041
60,000
42,722
3.88%,
3/01/2052
100,000
78,951
808,706
Transportation
3.2%
Canadian
National
Railway
Co.,
4.40%,
8/05/2052
23,000
21,134
Canadian
Pacific
Railway
Co.
1.75%,
12/02/2026
50,000
44,958
2.45%,
12/02/2031
8,000
7,011
CSX
Corp.,
3.95%,
5/01/2050
90,000
73,715
FedEx
Corp.,
4.75%,
11/15/2045
84,000
74,739
Ryder
System,
Inc.,
5.65%,
3/01/2028
80,000
80,120
Simpar
Europe
SA,
5.20%,
1/26/2031
(a)
200,000
158,951
Union
Pacific
Corp.
2.15%,
2/05/2027
225,000
205,715
4.95%,
9/09/2052
58,000
57,657
724,000
Total
Corporate
Bonds
(cost
$23,812,219)
22,162,876
Municipal
Securities
0.1%
California
Health
Facilities
Financing
Authority,
RB,
Series
2022,
4.35%,
6/01/2041
10,000
9,226
Total
Municipal
Securities
(cost
$10,000)
9,226
U.S.
Treasury
Government
Securities
0.5%
U.S.
Treasury
Bonds
3.88%,
2/15/2043
31,000
30,235
4.00%,
11/15/2052
84,000
86,310
Total
U.S.
Treasury
Government
Securities
(cost
$117,017)
116,545
Shares
Investment
Companies
0.4%
Registered
Investment
Companies
0.4%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.07%
(d)(e)
(cost
$100,316)
100,316
100,316
Investment
of
Cash
Collateral
for
Securities
Loaned
1.3%
Registered
Investment
Companies
1.3%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.07%
(d)(e)
(cost
$299,170)
299,170
299,170
Total
Investments
(cost
$24,338,722)
100.0%
22,688,133
Liabilities,
Less
Cash
and
Receivables
0.0%
(6,241)
Net
Assets
100.0%
22,681,892
STATEMENT
OF
INVESTMENTS
(continued)
18
RB—Revenue
Bond
(a)
Security
exempt
from
registration
pursuant
to
Rule
144A
under
the
Securities
Act
of
1933.
These
securities
may
be
resold
in
transactions
exempt
from
registration,
normally
to
qualified
institutional
buyers.
At
June
30,
2023,
these
securities
were
valued
at
$5,167,296
or
22.78%
of
net
assets.
(b)
Security,
or
portion
thereof,
on
loan.
At
June
30,
2023,
the
value
of
the
fund’s
securities
on
loan
was
$290,139
and
the
value
of
the
collateral
was
$299,170,
consisting
of
cash
collateral.
In
addition,
the
value
of
collateral
may
include
pending
sales
that
are
also
on
loan.
(c)
Perpetual
bond
with
no
specified
maturity
date.
(d)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(e)
The
rate
shown
is
the
1-day
yield
as
of
June
30,
2023.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
June
30,
2023
are
as
follows:
Description
Value
6/30/22
Purchases
($)
1
Sales
($)
Value
6/30/23
Dividends/
Distributions
($)
Investment
Companies
0.4%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
358,629
6,274,141
(6,532,454)
100,316
7,645
Investment
of
Cash
Collateral
for
Securities
Loaned
1.3%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
426,428
4,339,544
(4,466,802)
299,170
2,147
2
Total
1.7%
785,057
10,613,685
(10,999,256)
399,486
9,792
1
Includes
reinvested
dividends/distributions.
2
Represents
securities
lending
income
earned
from
the
reinvestment
of
cash
collateral
from
loaned
securities,
net
of
fees
and
collateral
investment
expenses,
and
other
payments
to
and
from
borrowers
of
securities.
Portfolio
Summary
(Unaudited)
Value
(%)
Financial
34.8
Consumer,
Non-cyclical
18.2
Technology
9.1
Energy
7.1
Consumer,
Cyclical
7.0
Communications
6.8
Industrial
5.8
Utilities
5.6
Basic
Materials
3.3
Registered
Investment
Companies
1.7
Government
0.6
100.0
Based
on
net
assets.
19
See
Notes
to
Financial
Statements
Futures
Description
Number
of
Contracts
Expiration
Notional
Value
($)
Market
Value
($)
Unrealized
Appreciation
(Depreciation)
($)
Futures
Long
U.S.
Treasury
Long
Bonds
11
9/20/2023
1,399,360
1,395,969
(3,391)
U.S.
Treasury
5
Year
Notes
7
9/29/2023
758,910
749,656
(9,254)
U.S.
Treasury
Ultra
Bonds
2
9/20/2023
269,757
272,438
2,681
Futures
Short
Euro-Buxl
2
9/7/2023
300,226
*
304,664
(4,438)
U.S.
Treasury
10
Year
Notes
3
9/20/2023
340,073
336,797
3,276
U.S.
Treasury
10
Year
Ultra
Notes
9
9/20/2023
1,079,621
1,065,938
13,683
Gross
Unrealized
Appreciation
19,640
Gross
Unrealized
Depreciation
(17,083)
*
Notional
amounts
in
foreign
currency
have
been
converted
to
USD
using
relevant
foreign
exchange
rates.
Forward
Foreign
Currency
Exchange
Contracts
Counterparty
/
Purchased
Currency
Purchased
Currency
Amounts
Currency
Sold
Sold
Currency
Amounts
Settlement
Date
Unrealized
Appreciation
(Depreciation)
($)
Goldman
Sachs
&
Co.
United
States
Dollar
123,443
Euro
112,000
7/18/2023
1,110
United
States
Dollar
222,057
Euro
205,000
8/8/2023
(2,099)
Gross
Unrealized
Appreciation
1,110
Gross
Unrealized
Depreciation
(2,099)
STATEMENT
OF
ASSETS
AND
LIABILITIES
June
30,
2023
20
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments
(including
securities
on
loan,
valued
at
$290,139)—Note
2(c):
Unaffiliated
issuers
23,939,236
22,288,647‌
Affiliated
issuers
399,486
399,486‌
Cash
denominated
in
foreign
currency
46
46‌
Interest
receivable
227,215‌
Receivable
for
futures
variation
margin—Note
4
72,065‌
Unrealized
appreciation
on
forward
foreign
currency
exchange
contracts—Note
4
1,110‌
Dividends
receivable
705‌
Securities
lending
income
receivable
385‌
22,989,659‌
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
6,498‌
Liability
for
securities
on
loan—Note
2(c)
299,170‌
Unrealized
depreciation
on
forward
foreign
currency
exchange
contracts—Note
4
2,099‌
307,767‌
Net
Assets
($)
22,681,892‌
Composition
of
Net
Assets
($):
Paid-in
capital
25,050,050‌
Total
distributable
earnings
(loss)
(2,368,158‌)
Net
Assets
($)
22,681,892‌
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
500,001‌
Net
asset
value
per
share
45.36‌
Market
price
per
share
45.47‌
STATEMENT
OF
OPERATIONS
Year
Ended
June
30,
2023
21
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Affiliated
issuers
7,645‌
Interest
978,821‌
Income
from
securities
lending—Note
2(c)
2,147‌
Total
Income
988,613‌
Expenses:
Management
fee—Note
3(a)
79,396‌
Total
Expenses
79,396‌
Net
Investment
Income
909,217‌
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
and
foreign
currency
transactions
(651,494‌)
Net
realized
gain
(loss)
on
futures
81,364‌
Net
realized
gain
(loss)
on
forward
foreign
currency
exchange
contracts
(1,984‌)
Net
realized
gain
(loss)
(572,114‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
and
foreign
currency
transactions
155,537‌
Net
change
in
unrealized
appreciation
(depreciation)
on
futures
(37,154‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
forward
foreign
currency
exchange
contracts
(13,271‌)
Net
change
in
unrealized
appreciation
(depreciation)
105,112‌
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
(467,002‌)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
442,215‌
STATEMENT
OF
CHANGES
IN
NET
ASSETS
22
See
Notes
to
Financial
Statements
Year
Ended
June
30,
2023
For
the
Period
from
March
22,
2022
(a)
to
June
30,
2022
Operations
($):
Net
investment
income
909,217‌
225,556‌
Net
realized
gain
(loss)
on
investments
(572,114‌)
(252,911‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
105,112‌
(1,753,981‌)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
442,215‌
(1,781,336‌)
Distributions
($):
Distributions
to
shareholders
(865,717‌)
(163,320‌)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
—‌
25,000,050‌
Transaction
fees—Note
5
—‌
50,000‌
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
—‌
25,050,050‌
Total
Increase
(Decrease)
in
Net
Assets
(423,502‌)
23,105,394‌
Net
Assets
($):
Beginning
of
Period
23,105,394‌
—‌
End
of
Period
22,681,892‌
23,105,394‌
Changes
in
Shares
Outstanding:
Shares
sold
—‌
500,001‌
Net
Increase
(Decrease)
in
Shares
Outstanding
—‌
500,001‌
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
23
The
following
table
describes
the
performance
for
the
fiscal
periods
indicated
and
these
figures
have
been
derived
from
the
fund’s
financial
statements.
See
Notes
to
Financial
Statements
Year
Ended
June
30,
2023
For
the
Period
from
March
22,
2022
(a)
to
June
30,
2022
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
46.21‌
50.00‌
Investment
Operations:
Net
investment
income
(b)
1.82‌
0.45‌
Net
realized
and
unrealized
gain
(loss)
on
investments
(0.94‌)
(4.01‌)
Total
from
Investment
Operations
0.88‌
(3.56‌)
Distributions:
Dividends
from
net
investment
income
(1.73‌)
(0.33‌)
Transaction
fees
(b)
—‌
0.10‌
Net
asset
value,
end
of
period
45.36‌
46.21‌
Market
price,
end
of
period
(c)
45.47‌
46.46‌
Net
Asset
Value
Total
Return
(%)
(d)
2.01‌
(6.94‌)
(e)
Market
Price
Total
Return
(%)
(d)
1.69‌
(6.44‌)
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.35‌
0.35‌
(f)
Ratio
of
net
investment
income
to
average
net
assets
4.01‌
3.41‌
(f)
Portfolio
Turnover
Rate
(g)
53.59‌
13.06‌
Net
Assets,
end
of
period
($
x
1,000)
22,682‌
23,105‌
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
The
mean
between
the
last
bid
and
ask
prices.
(d)
Net
asset
value
total
return
is
calculated
assuming
an
initial
investment
made
at
the
net
asset
value
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
net
asset
value
during
the
period,
and
redemption
at
net
asset
value
on
the
last
day
of
the
period.
Net
asset
value
total
return
includes
adjustments
in
accordance
with
accounting
principles
generally
accepted
in
the
United
States
of
America
and
as
such,
the
net
asset
value
for
financial
reporting
purposes
and
the
returns
based
upon
those
net
asset
values
may
differ
from
the
net
asset
value
and
returns
for
shareholder
transactions.
Market
price
total
return
is
calculated
assuming
an
initial
investment
made
at
the
market
price
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
market
price
during
the
period,
and
sale
at
the
market
price
on
the
last
day
of
the
period.
Total
investment
returns
calculated
for
a
period
of
less
than
one
year
are
not
annualized.
(e)
The
net
asset
value
total
return
and
the
market
price
total
return
is
calculated
from
fund
inception.
(f)
Annualized.
(g)
Portfolio
turnover
rate
is
not
annualized
for
periods
less
than
one
year,
if
applicable,
and
does
not
include
securities
received
or
delivered
from
processing
creations
or
redemptions.
NOTES
TO
FINANCIAL
STATEMENTS
24
NOTE
1—Organization:
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF (the “fund”) is a
separate
diversified series
of
BNY
Mellon
ETF
Trust
(the
“Trust”),
which is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-ended
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
seventeen
series,
including
the
fund.
The
investment
objective
of
the
fund
is
to
seek
total
return
consisting
of
capital
appreciation
and
income.
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
a
wholly-owned
subsidiary
of
The
Bank
of
New
York
Mellon
Corporation
(“BNY
Mellon”),
serves
as
the
fund’s
investment
adviser. Insight
North
America
LLC (the
“Sub-Adviser”
or
“Insight”),
an
indirect wholly-owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-adviser.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“fund’s
Shares.”
The
fund’s
Shares
are
listed
and
traded
on
NYSE
Arca,
Inc.
The
market
price
of
each
Share
may
differ
to
some
degree
from
the
fund’s
net
asset
value
(“NAV”).
Unlike
conventional
mutual
funds,
the
fund
issues
and
redeems
Shares
on
a
continuous
basis,
at
NAV,
only
in
a
large
specified
number
of
Shares,
each
called
a
“Creation
Unit.”
Creation
Units
are
issued
and
redeemed
principally
in
exchange
for
the
deposit
or
delivery
of
a
basket
of
securities.
Except
when
aggregated
in
Creation
Units
by
Authorized
Participants,
the
Shares
are
not
individually
redeemable
securities
of
the
fund.
Individual
fund
Shares
may
only
be
purchased
and
sold
on
the
NYSE
Arca,
Inc.,
other
national
securities
exchanges,
electronic
crossing
networks
and
other
alternative
trading
systems
through
your
broker-dealer
at
market
prices.
Because
fund
Shares
trade
at
market
prices
rather
than
at
NAV,
fund
Shares
may
trade
at
a
price
greater
than
NAV
(premium)
or
less
than
NAV
(discount).
When
buying
or
selling
Shares
in
the
secondary
market,
you
may
incur
costs
attributable
to
the
difference
between
the
highest
price
a
buyer
is
willing
to
pay
to
purchase
Shares
of
the
fund
(bid)
and
the
lowest
price
a
seller
is
willing
to
accept
for
Shares
of
the
fund
(ask). 
NOTE
2—Significant
Accounting
Policies: 
The
Financial
Accounting
Standards
Board
(“FASB”)
Accounting
Standards
Codification
(“ASC”)
is
the
exclusive
reference
of
authoritative
U.S.
generally
accepted
accounting
principles
(“GAAP”)
recognized
by
the
FASB
to
be
applied
by
nongovernmental
entities.
Rules
and
interpretive
releases
of
the
SEC
under
authority
of
federal
laws
are
also
sources
of
authoritative
GAAP
for
SEC
registrants. The
fund
is an
investment
company
and
applies
the
accounting
and
reporting
guidance
of
the
FASB
ASC
Topic
946
Financial
Services-Investment
Companies. The
fund’s
25
financial
statements
are
prepared
in
accordance
with
GAAP,
which
may
require
the
use
of
management
estimates
and
assumptions.
Actual
results
could
differ
from
those
estimates.  
The
Trust
accounts
separately
for
the
assets,
liabilities
and
operations
of
each
series.
Expenses
directly
attributable
to
each
series
are
charged
to
that
series’
operations;
expenses
which
are
applicable
to
all
series
are
allocated
among
them
on
a
pro
rata
basis.
The
Trust
enters
into
contracts
that
contain
a
variety
of
indemnifications.
The
fund’s
maximum
exposure
under
these
arrangements
is
unknown.
The
fund
does
not
anticipate
recognizing
any
loss
related
to
these
arrangements. 
(a)
Portfolio
valuation:
The
fair
value
of
a
financial
instrument
is
the
amount
that
would
be
received
to
sell
an
asset
or
paid
to
transfer
a
liability
in
an
orderly
transaction
between
market
participants
at
the
measurement
date
(i.e.,
the
exit
price).
GAAP
establishes
a
fair
value
hierarchy
that
prioritizes
the
inputs
of
valuation
techniques
used
to
measure
fair
value.
This
hierarchy
gives
the
highest
priority
to
unadjusted
quoted
prices
in
active
markets
for
identical
assets
or
liabilities
(Level
1
measurements)
and
the
lowest
priority
to
unobservable
inputs
(Level
3
measurements).
Additionally,
GAAP
provides
guidance
on
determining
whether
the
volume
and
activity
in
a
market
has
decreased
significantly
and
whether
such
a
decrease
in
activity
results
in
transactions
that
are
not
orderly.
GAAP
requires
enhanced
disclosures
around
valuation
inputs
and
techniques
used
during
annual
and
interim
periods.
Various
inputs
are
used
in
determining
the
value
of
the
fund’s
investments
relating
to
fair
value
measurements.
These
inputs
are
summarized
in
the
three
broad
levels
listed
below:
Level
1
unadjusted
quoted
prices
in
active
markets
for
identical
investments.
Level
2
other
significant
observable
inputs
(including
quoted
prices
for
similar 
investments,
interest
rates,
prepayment
speeds,
credit
risk,
etc.).
Level
3
significant
unobservable
inputs
(including
the
fund’s
own
assumptions
in
determining
the
fair
value
of
investments).
The
inputs
or
methodology
used
for
valuing
securities
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
those
securities.
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value
and
are
generally
categorized
within
Level 1
of
the
fair
value
hierarchy.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
26
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
debt
securities
excluding
short-term
investments
(other
than
U.S.
Treasury
Bills),
futures
and
forward
foreign
currency
exchange
contracts
(“forward
contracts”)
are
valued
each
business
day
by
one
or
more
independent
pricing
services
(each,
a
“Service”)
approved
by the Board.
Investments
for
which
quoted
bid
prices
are
readily
available
and
are
representative
of
the
bid
side
of
the
market
in
the
judgment
of
a
Service
are
valued
at
the
mean
between
the
quoted
bid
prices
(as
obtained
by
a
Service
from
dealers
in
such
securities)
and
asked
prices
(as
calculated
by
a
Service
based
upon
its
evaluation
of
the
market
for
such
securities).
Securities
are
valued
as
determined
by
a
Service,
based
on
methods
which
include
consideration
of
the
following:
yields
or
prices
of
securities
of
comparable
quality,
coupon,
maturity
and
type;
indications
as
to
values
from
dealers;
and
general
market
conditions.
Each
Service
and
independent
valuation
firm
is
engaged
under
the
general
oversight
of
the
Board.
Overnight
and
certain
other
short-term
debt
instruments
(excluding
U.S.
Treasury
Bills)
will
be
valued
by
the
amortized
cost
method,
which
approximates
value,
unless
a
Service
provides
a
valuation
for
such
security
or,
in
the
opinion
of
the
Board
or
a
committee
or
other
persons
designated
by
the
Board,
the
amortized
cost
method
would
not
represent
fair
value. These
securities
are
generally
categorized
within
Level
2
of
the
fair
value
hierarchy.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
Futures,
which
are
traded
on
an
exchange,
are
valued
at
the
last
sales
price
on
securities
exchange
on
which
such
contracts
are
primarily
traded
or
at
the
last
sales
price
on
the
exchange
on
each
business
day
and
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy.
Forward
contracts
are
valued
at
the
forward
rate
and
are
generally
categorized
within
Level
2
of
the
fair
value
hierarchy.
27
The
table
below
summarizes
the
inputs
used
as
of June
30,
2023
in
valuing
the
fund’s
investments:
Fair
Value
Measurements
(b)
Foreign
currency
transactions:
The
fund
does
not
isolate
that
portion
of
the
results
of
operations
resulting
from
changes
in
foreign
exchange
rates
on
investments
from
the
fluctuations
arising
from
changes
in
the
market
prices
of
securities
held.
Such
fluctuations
are
included
with
the
net
realized
and
unrealized
gain
or
loss
on
investments.
Net
realized
foreign
exchange
gains
or
losses
arise
from
sales
of
foreign
currencies,
currency
gains
or
losses
realized
on
securities
transactions
between
trade
and
settlement
date,
and
the
difference
between
the
amounts
of
dividends,
interest
and
foreign
withholding
taxes
recorded
on
the
fund’s
books
and
the
U.S.
dollar
equivalent
of
the
amounts
actually
received
or
paid.
Net
unrealized
foreign
exchange
gains
and
losses
arise
from
changes
in
the
value
of
assets
and
liabilities
other
than
investments
resulting
from
changes
in
exchange
rates.
Foreign
currency
gains
and
losses
on
foreign
currency
transactions
are
also
included
with
net
realized
and
unrealized
gain
or
loss
on
investments.
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
Corporate
Bonds
22,162,876
22,162,876
Municipal
Securities
9,226
9,226
U.S.
Treasury
Government
Securities
116,545
116,545
Investment
Companies
100,316
100,316
Investment
of
Cash
Collateral
for
Securities
Loaned
299,170
299,170
Other
Financial
Instruments:
Futures
††
19,640
19,640
Forward
Foreign
Currency
Exchange
Contracts
††
1,110
1,110
Liabilities
($)
Other
Financial
Instruments:
Futures
††
(17,083)
(17,083)
Forward
Foreign
Currency
Exchange
Contracts
††
(2,099)
(2,099)
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
††
Amount
shown
represents
unrealized
appreciation
(depreciation)
at
period
end,
but
only
variation
margin
on
exchange-
traded
and
centrally
cleared
derivatives,
if
any,
are
reported
in
the
Statement
of
Assets
and
liabilities.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
28
Foreign
Taxes:
The
fund
may
be
subject
to
foreign
taxes
(a
portion
of
which
may
be
reclaimable)
on
income,
stock
dividends,
realized
and
unrealized
capital
gains
on
investments
or
certain
foreign
currency
transactions.
Foreign
taxes
are
recorded
in
accordance
with
the
applicable
foreign
tax
regulations
and
rates
that
exist
in
the
foreign
jurisdictions
in
which
the
fund
invests.
These
foreign
taxes,
if
any,
are
paid
by
the
fund
and
are
reflected
in
the
Statement
of
Operations,
if
applicable.
Foreign
taxes
payable
or
deferred
or
those
subject
to
reclaims as
of June
30,
2023,
if
any,
are
disclosed
in
the
fund’s
Statement
of
Assets
and
Liabilities.
(c)
Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-
dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
Pursuant
to
a
securities
lending
agreement
with
BNY
Mellon,
the
fund
may
lend
securities
to
qualified
institutions.
It
is
the
fund’s
policy
that,
at
origination,
all
loans
are
secured
by
collateral
of
at
least
102%
of
the
value
of
U.S.
securities
loaned
and
105%
of
the
value
of
foreign
securities
loaned.
Collateral
equivalent
to
at
least
100%
of
the
market
value
of
securities
on
loan
is
maintained
at
all
times.
Collateral
is
either
in
the
form
of
cash,
which
can
be
invested
in
certain
money
market
mutual
funds
managed
by
the
Adviser,
or
U.S.
Government
and
Agency
securities.
The
fund is
entitled
to
receive
all
dividends,
interest
and
distributions
on
securities
loaned,
in
addition
to
income
earned
as
a
result
of
the
lending
transaction.
Should
a
borrower
fail
to
return
the
securities
in
a
timely
manner,
BNY
Mellon
is
required
to
replace
the
securities
for
the
benefit
of
the
fund
or
credit
the
fund
with
the
market
value
of
the
unreturned
securities
and
is
subrogated
to
the
fund’s
rights
against
the
borrower
and
the
collateral.
Additionally,
the
contractual
maturity
of
security
lending
transactions
are
on
an
overnight
and
continuous
basis.
During
the
year
ended
June
30,
2023,
BNY
Mellon
earned
$293 from
the
lending
of
the
fund’s portfolio
securities,
pursuant
to
the
securities
lending
agreement.
(d)
Affiliated
issuers:
Investments
in
other
investment
companies
advised
by
the
Adviser
are
defined
as
“affiliated”
under
the
Act. 
(e)
Market
Risk:
The
value
of
the
securities
in
which
the
fund
invests
may
be
affected
by
political,
regulatory,
economic
and
social
developments,
and
developments
that
impact
specific
economic
sectors,
industries
or
segments
of
the
market.
The
value
of
a
security
may
also
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
company
or
industry,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
the
general
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates,
changes
to
inflation,
adverse
changes
to
credit
markets
or
adverse
investor
sentiment
generally.
In
addition,
turbulence
in
financial
markets
and
reduced
liquidity
in
equity,
credit
and/or
fixed
income
markets
may
negatively
affect
many
29
issuers,
which
could
adversely
affect
the
fund.
Global
economies
and
financial
markets
are
becoming
increasingly
interconnected,
and
conditions
and
events
in
one
country,
region
or
financial
market
may
adversely
impact
issuers
in
a
different
country,
region
or
financial
market.
These
risks
may
be
magnified
if
certain
events
or
developments
adversely
interrupt
the
global
supply
chain;
in
these
and
other
circumstances,
such
risks
might
affect
companies
world-wide.
Recent
examples
include
pandemic
risks
related
to
COVID-19
and
aggressive
measures
taken
world-wide
in
response
by
governments,
including
closing
borders,
restricting
international
and
domestic
travel,
and
the
imposition
of
prolonged
quarantines
of
large
populations,
and
by
businesses,
including
changes
to
operations
and
reducing
staff.
ESG
Investment
Approach
Risk:
The
fund’s
incorporation
of
ESG
considerations
into
its
investment
approach
may
cause
it
to
make
different
investments
than
funds
that
invest
principally
in
corporate
bonds
but
do
not
incorporate
ESG
considerations
when
selecting
investments.
Under
certain
economic
conditions,
this
could
cause
the
fund
to
underperform
funds
that
do
not
incorporate
ESG
considerations.
For
example,
the
incorporation
of
ESG
considerations
may
result
in
the
fund
forgoing
opportunities
to
buy
certain
securities
when
it
might
otherwise
be
advantageous
to
do
so
or
selling
securities
when
it
might
otherwise
be
disadvantageous
for
the
fund
to
do
so.
The
incorporation
of
ESG
considerations
may
also
affect
the
fund’s
exposure
to
certain
sectors
and/or
types
of
investments,
and
may
adversely
impact
the
fund’s
performance
depending
on
whether
such
sectors
or
investments
are
in
or
out
of
favor
in
the
market.
Insight’s
security
selection
process
incorporates
ESG
data
provided
by
third
parties,
which
may
be
limited
for
certain
issuers
and/or
only
take
into
account
one
or
a
few
ESG
related
components.
In
addition,
ESG
data
may
include
quantitative
and/or
qualitative
measures,
and
consideration
of
this
data
may
be
subjective.
Different
methodologies
may
be
used
by
the
various
data
sources
that
provide
ESG
data.
ESG
data
from
third
parties
used
by
Insight
as
part
of
its
proprietary
ESG
process
often
lacks
standardization,
consistency
and
transparency,
and
for
certain
issuers
such
data
may
not
be
available
complete
or
accurate.
Insight’s
evaluation
of
ESG
factors
relevant
to
a
particular
issuer
may
be
adversely
affected
in
such
instances.
As
a
result,
the
fund’s
investments
may
differ
from,
and
potentially
underperform,
funds
that
incorporate
ESG
data
from
other
sources
or
utilize
other
methodologies.
Foreign
Investment
Risk:
Because
the
fund
invests
in
foreign
securities,
the
fund’s
performance
will
be
influenced
by
political,
social
and
economic
factors
affecting
investments
in
foreign
issuers.
Special
risks
associated
with
investments
in
foreign
issuers
include
exposure
to
currency
fluctuations,
less
liquidity,
less
developed
or
less
efficient
trading
markets,
lack
of
comprehensive
company
information,
political
and
economic
instability
and
differing
auditing
and
legal
standards.
The
imposition
of
sanctions,
confiscations,
trade
restrictions
(including
tariffs)
and
other
government
restrictions
by
the
United
States
and
other
governments,
or
problems
in
share
registration,
settlement
or
custody,
may
result
in
losses
for
the
fund.
Investments
denominated
in
foreign
currencies
are
subject
to
the
risk
that
such
currencies
will
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
30
decline
in
value
relative
to
the
U.S.
dollar
and
affect
the
value
of
these
investments
held
by
the
fund.
Some
sovereign
obligors
have
been
among
the
world’s
largest
debtors
to
commercial
banks,
other
governments,
international
financial
organizations
and
other
financial
institutions.
These
obligors,
in
the
past,
may
have
experienced
substantial
difficulties
in
servicing
their
external
debt
obligations,
which
led
to
defaults
on
certain
obligations
and
the
restructuring
of
certain
indebtedness.
To
the
extent
securities
held
by
the
fund
trade
in
a
market
that
is
closed
when
the
exchange
on
which
the
fund's
shares
trade
is
open,
there
may
be
deviations
between
the
current
price
of
a
security
and
the
last
quoted
price
for
the
security
in
the
closed
foreign
market.
These
deviations
could
result
in
the
fund
experiencing
premiums
or
discounts
greater
than
those
of
ETFs
that
invest
in
domestic
securities.
Debt
Risk:
The
fund
invests
in
debt
securities.
Failure
of
an
issuer
of
the
debt
securities
to
make
timely
interest
or
principal
payments,
or
a
decline
or
the
perception
of
a
decline
in
the
credit
quality
of
a
debt
security,
can
cause
the
debt
security’s
price
to
fall,
potentially
lowering
the
fund’s
share
price.
High
Yield
(“junk”)
bonds
involve
greater
credit
risk,
including
the
risk
of
default,
than
investment
grade
bonds,
and
are
considered
predominantly
speculative
with
respect
to
the
issuer’s
continuing
ability
to
make
principal
and
interest
payments.
In
addition,
the
value
of
debt
securities
may
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
issuer,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates
or
adverse
investor
sentiment.
They
may
also
decline
because
of
factors
that
affect
a
particular
industry.
(f)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions
are
recorded
on
the
ex-dividend
date.
Dividends
from
net
investment
income
are
normally
declared
and
paid
on
a
monthly
basis. Dividends
from
net
realized
capital
gains,
if
any,
are
normally
declared
and
paid
annually,
but
the
fund
may
make
distributions
on
a
more
frequent
basis
to
comply
with
the
distribution
requirements
of
the
Internal
Revenue
Code
of
1986,
as
amended
(the
“Code”).
To
the
extent
that
net
realized
capital
gains
can
be
offset
by
capital
loss
carryovers
of
a
fund,
it
is
the
policy
of
the
fund
not
to
distribute
such
gains.
Income
and
capital
gain
distributions
are
determined
in
accordance
with
income
tax
regulations,
which
may
differ
from
GAAP.
(g)
Federal
income
taxes:
It
is
the
policy
of
the
fund
to
continue to
qualify
as
a
regulated
investment
company,
if
such
qualification
is
in
the
best
interests
of
its
shareholders,
by
complying
with
the
applicable
provisions
of
the
Code,
and
to
make
distributions
of
taxable
income
and
net
realized
capital
gain sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
For
federal
income
tax
purposes,
the
fund
is
treated
as
a
separate
entity.
31
As
of
and
during
the period
ended June
30,
2023,
the
fund
did
not
have
any
liabilities
for
any
uncertain
tax
positions.
The
fund
recognizes
interest
and
penalties,
if
any,
related
to
uncertain
tax
positions
as
income
tax
expense
in
the
Statement
of
Operations.
During
the period
ended June
30,
2023,
the
fund
did
not
incur
any
interest
or
penalties.
Each
tax
year
in
the
two-year
period
ended June
30,
2023
remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities.
At June
30,
2023,
the
components
of
accumulated
earnings
on
a
tax
basis
were
as
follows:
undistributed
ordinary
income
$164,499,
accumulated
capital
losses
$851,515, and
unrealized depreciation
$1,681,142.
The
fund is
permitted
to
carry
forward
capital
losses
for
an
unlimited
period.
Furthermore,
capital
loss
carryovers
retain
their
character
as
either
short-term
or
long-
term
capital
losses.
The
accumulated
capital
loss
carryover
is
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
June
30,
2023.
The
fund
has
$798,748
of
short-term
capital
losses
and
$52,767
of
long-
term
capital
losses
which
can
be
carried
forward
for
an
unlimited
period.
The
tax
character
of
distributions
paid
to
shareholders
during
the
fiscal
years
ended
June
30,
2023
and
June
30,
2022
were
as
follows:
ordinary
income
$865,717
and
$163,320,
respectively.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.35%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expense,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
June
30,
2023,
there
was
no
reduction
in
expenses
pursuant
to
the
undertaking.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Sub-Adviser
serves
as
the
fund’s
sub-adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
Sub-Adviser
a
monthly
fee
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
32
at
an
annual
percentage
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser
has
obtained
an
exemptive
order
from
the
SEC
(the
“Order”),
upon
which
the
fund
may
rely,
to
use
a
manager
of
managers
approach
that
permits
the
Adviser,
subject
to
certain
conditions
and
approval
by
the
Board,
to
enter
into
and
materially
amend
sub-investment
advisory
agreements
with
one
or
more
sub-advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-advisory
fee
paid
by
the
Adviser
to
a
Sub-Adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-advisory
fee
payable
by
the
Adviser
separately
to
a
Sub-Adviser
that
is
a
wholly-owned
subsidiary
(as
defined
in
the
1940
Act)
of
BNY
Mellon
in
documents
filed
with
the
SEC
and
provided
to
shareholders;
such
fees
are
to
be
aggregated
with
fees
payable
to
the
Adviser.
The
Adviser
has
ultimate
responsibility
(subject
to
oversight
by
the
Board)
to
supervise
any
Sub-Adviser
and
recommend
the
hiring,
termination,
and
replacement
of
any
Sub-Adviser
to
the
Board.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
rate
of
0.175%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser,
and
not
the
fund,
pays
the
Sub-Adviser
fee
rate.
(b)
The
fund
has
an
arrangement
with
The
Bank
of
New
York
Mellon
(the
“Custodian”),
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser, whereby
the
fund
will
receive
interest
income
or
be
charged
overdraft
fees
when
cash
balances
are
maintained.
For
financial
reporting
purposes,
the
fund
includes
this
interest
income
and
overdraft
fees,
if
any,
as
interest
income
in
the
Statement
of
Operations.
The
components
of
“Due
to
BNY
Mellon
ETF Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fee
of $6,498.
(c)
Each
Board
member
serves
as
a
Board
member
of
each
fund
within
the
Trust.
The
Board
members
are
not
compensated
directly
by
the
fund.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fee
paid
to
the
Adviser
by
the
fund.
The
quarterly
fees
are
paid
by
the
Adviser
from
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Trust,
including
the
fund.
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
(including
paydowns,
if
any)
of
investment
securities,
excluding
short-term
securities,
futures,
forward
contracts
and
in-kind
transactions,
during
the
period
ended
June
30,
2023, amounted
to $12,119,875
and
$11,927,997,
respectively.
Derivatives:
A
derivative
is
a
financial
instrument
whose
performance
is
derived
from
the
performance
of
another
asset.
The
fund
enters
into
International
Swaps
and
Derivatives
Association,
Inc.
Master
Agreements
or
similar
agreements
(collectively,
33
“Master
Agreements”)
with
its
over-the-counter
(“OTC”)
derivative
contract
counterparties
in
order
to,
among
other
things,
reduce
its
credit
risk
to
counterparties.
Master
Agreements
include
provisions
for
general
obligations,
representations,
collateral
and
events
of
default
or
termination.
Under
a
Master
Agreement,
the
fund
may
offset
with
the
counterparty
certain
derivative
financial
instruments’
payables
and/
or
receivables
with
collateral
held
and/or
posted
and
create
one
single
net
payment
in
the
event
of
default
or
termination.
The
SEC
adopted
Rule
18f-4
under
the
Act,
which
regulates
the
use
of
derivative
transactions
for
certain
funds
registered
under
the
Act.
The
fund’s
derivative
transactions
are
subject
to
a
value-at-risk
leverage
limit
and
certain
reporting
and
other
requirements
pursuant
to
a
derivatives
risk
management
program
adopted
by
the
fund.
Each
type
of
derivative
instrument
that
was
held
by
the
fund
during
the year
ended
June
30,
2023
is
discussed
below.
Futures:
In
the
normal
course
of
pursuing
its
investment
objective,
exposed
to
market
risk,
including
interest
risk,
as
a
result
of
changes
in
value
of
underlying
financial
instruments.
The
fund
invests
in
futures
in
order
to
manage
the
exposure
to
or
protect
against
changes
in
the
market.
A
futures
contract
represents
a
commitment
for
the
future
purchase
or
a
sale
of
an
asset
at
a
specified
date.
Upon
entering
into
such
contracts,
these
investments
require
initial
margin
deposits
with
a
counterparty,
which
consist
of
cash
or
cash
equivalents.
The
amount
of
these
deposits
is
determined
by
the
exchange
or
Board
of
Trade
on
which
the
contract
is
traded
and
is
subject
to
change.
Accordingly,
variation
margin
payments
are
received
or
made
to
reflect
daily
unrealized
gains
or
losses
which
are
recorded
in
the
Statements
of
Operations.
When
the
contracts
are
closed,
the
fund
recognizes
a
realized
gain
or
loss
which
is
reflected
in
the
Statements
of
Operations.
There
is
minimal
counterparty
credit
risk
to
the
fund
with
futures
since
they
are
exchange
traded,
and
the
exchange
guarantees
the
futures
against
default.
Futures
open
at June
30,
2023,
are
set
forth
in
the
Statement
of
Investments.
Forward
Foreign
Currency
Exchange
Contracts:
The
fund
enters
into
forward
contracts
in
order
to
hedge
its
exposure
to
changes
in
foreign
currency
exchange
rates
on
its
foreign
portfolio
holdings,
to
settle
foreign
currency
transactions
or
as
a
part
of
its
investment
strategy.
When
executing
forward
contracts,
the
fund
is
obligated
to
buy
or
sell
a
foreign
currency
at
a
specified
rate
on
a
certain
date
in
the
future.
With
respect
to
sales
of
forward
contracts,
the
fund
incurs
a
loss
if
the
value
of
the
contract
increases
between
the
date
the
forward
contract
is
opened
and
the
date
the
forward
contract
is
closed.
The
fund
realizes
a
gain
if
the
value
of
the
contract
decreases
between
those
dates.
With
respect
to
purchases
of
forward
contracts,
the
fund
incurs
a
loss
if
the
value
of
the
contract
decreases
between
the
date
the
forward
contract
is
opened
and
the
date
the
forward
contract
is
closed.
The
fund
realizes
a
gain
if
the
value
of
the
contract
increases
between
those
dates.
Any
realized
or
unrealized
gains
or
losses
which
occurred
during
the
period
are
reflected
in
the
Statement
of
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
34
Operations.
The
fund
is
exposed
to
foreign
currency
risk
as
a
result
of
changes
in
value
of
underlying
financial
instruments.
The
fund
is
also
exposed
to
credit
risk
associated
with
counterparty
nonperformance
on
these
forward
contracts,
which
is
generally
limited
to
the
unrealized
gain
on
each
open
contract.
This
risk
may
be
mitigated
by
Master
Agreements,
if
any,
between
the
fund
and
the
counterparty
and
the
posting
of
collateral,
if
any,
by
the
counterparty
to
the
fund
to
cover
the
fund’s
exposure
to
the
counterparty.
Forward
contracts
open
at June
30,
2023
are
set
forth
in
the
Statement
of
Investments.
The
following
tables
show
the
fund’s
exposure
to
different
types
of
market
risk
as
it
relates
to
the
Statement
of
Assets
and
Liabilities
and
the
Statement
of
Operations,
respectively. 
Fair
value
of
derivative
instruments
as
of June
30,
2023
is
shown
below:
Statement
of
Assets
and
Liabilities
location:
The
effect
of
derivative
instruments
in
the
Statements of
Operations
during
the year
ended
June
30,
2023 is
shown
below:
Statement
of
Operations
location:
Derivative
Assets
($)
Derivative
Liabilities
($)
Interest
rate
risk
19,640
(a)
Interest
rate
risk
(17,083)
(a)
Foreign
exchange
risk
1,110
(b)
Foreign
exchange
risk
(2,099)
(b)
Gross
fair
value
of
derivative
contracts
20,750
(19,182)
(a)
Includes
cumulative
appreciation
(depreciation)
on
futures
as
reported
in
the
Statement
of
Investments,
but
only
the
unpaid
variation
margin
is
reported
in
the
Statement
of
Assets
and
Liabilities.
(b)
Unrealized
appreciation
(depreciation)
on
forward
foreign
currency
exchange
contracts.
Amount
of
realized
gain
(loss)
on
derivatives
recognized
in
income
($)
Underlying
Risk
Futures
(a)
Forward
Contracts
(b)
Total
Interest
rate
81,364
81,364
Foreign
exchange
(1,984)
(1,984)
Total
81,364
(1,984)
79,380
Net
change
in
unrealized
appreciation
(depreciation)
on
derivatives
recognized
in
income
($)
Underlying
Risk
Futures
(c)
Forward
Contracts
(d)
Total
Interest
rate
(37,154)
(37,154)
Foreign
exchange
(13,271)
(13,271)
Total
(37,154)
(13,271)
(50,425)
(a)
Net
realized
gain
(loss)
on
futures.
(b)
Net
realized
gain
(loss)
on
forward
foreign
currency
exchange
contracts.
(c)
Net
change
in
unrealized
appreciation
(depreciation)
on
futures.
(d)
Net
change
in
unrealized
appreciation
(depreciation)
on
forward
foreign
currency
exchange
contracts.
35
The
provisions
of
ASC
Topic
210
“Disclosures
about
Offsetting
Assets
and
Liabilities”
require
disclosure
on
the
offsetting
of
financial
assets
and
liabilities.
These
disclosures
are
required
for
certain
investments,
including
derivative
financial
instruments
subject
to
Master
Agreements
which
are
eligible
for
offsetting
in
the
Statement
of
Assets
and
Liabilities
and
require
the
fund
to
disclose
both
gross
and
net
information
with
respect
to
such
investments.
For
financial
reporting
purposes,
the
fund
does
not
offset
derivative
assets
and
derivative
liabilities
that
are
subject
to
Master
Agreements
in
the
Statement
of
Assets
and
Liabilities.
At June
30,
2023,
derivative
assets
and
liabilities
(by
type)
on
a
gross
basis
are
as
follows:
The
following
tables
present
derivative
assets
and
liabilities
net
of
amounts
available
for
offsetting
under
Master
Agreements
and
net
of
related
collateral
received
or
pledged,
if
any,
as
of June
30,
2023:
The following
table summarizes
the
average market
value of
derivatives
outstanding
during
the year
ended
June
30,
2023:
At June
30,
2023,
the
cost
of
investments
for
federal
income
tax
purposes
was
$24,369,275;
accordingly,
accumulated
net
unrealized
depreciation on
investments
for
federal
income
tax
purposes
was
$1,681,142,
consisting
of
gross
appreciation
of
$72,040
and
gross
depreciation
of
$1,753,182.
Derivative
Financial
Instruments:
Assets
($)
Liabilities
($)
Futures
19,640
(17,083)
Forward
contracts
1,110
(2,099)
Total
gross
amount
of
derivative
assets
and
liabilities
in
the
Statement
of
Assets
and
Liabilities
20,750
(19,182)
Derivatives
not
subject
to  Master
Agreements
19,640
(17,083)
Total
gross
amount
of
derivative
assets
and
liabilities
subject
to
Master
Agreements
1,110
(2,099)
Counterparty
Gross
Amount
of
Assets
($)
Financial
Instruments
and
Derivatives
Available
for
Offset
($)
Collateral
Received
($)
Net
Amount
of
Assets
($)
Goldman
Sachs
&
Co.
1,110
(1,110)
Counterparty
Gross
Amount
of
Liabilities($)
Financial
Instruments
and
Derivatives
Available
for
Offset
($)
Collateral
Pledged
($)
Net
Amount
of
Liabilities
($)
Goldman
Sachs
&
Co.
(2,099)
1,110
(989)
Absent
a
default
event
or
early
termination,
OTC
derivative
assets
and
liabilities
are
presented
at
gross
amounts
and
are
not
offset
in
the
Statement
of
Assets
and
Liabilities.
Average
Market
Value
($)
Interest
rate
futures
2,789,910
Forward
contracts
848,824
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
36
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
in-kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
As
of
June
30,
2023,
BNY
Mellon
held
490,001
shares
of
the
fund.
In-kind
Redemptions:
For
financial
reporting
purposes,
in-kind
redemptions
are
treated
as
sales
of
securities
resulting
in
realized
capital
gains
or
losses
to
the
fund.
Because
such
gains
or
losses
are
not
taxable
to
the
fund
and
are
not
distributed
to
existing
fund
shareholders,
the
gains
or
losses
are
reclassified
from
accumulated
net
realized
gain
(loss)
to
paid-in
capital
at
the
end
of
the
fund’s
tax
year.
These
reclassifications
have
no
effect
on
net
assets
or
net
asset
value
per
share.
During
the
year
ended
June
30,
2023,
the
fund
had
no
in-kind
transactions.
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
37
To
the
Shareholders
and
the
Board
of
Trustees
of
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
(the
“Fund”)
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust
(the
“Trust”)),
including
the
statement
of
investments,
as
of
June
30,
2023,
and
the
related
statement
of
operations
for
the
year
then
ended,
the
statements
of
changes
in
net
assets
and
the
financial
highlights
for
the
year
ended
June
30,
2023
and
the
period
from
March
22,
2022
(commencement
of
operations)
through
June
30,
2022
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Fund
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust)
at
June
30,
2023,
the
results
of
its
operations
for
the
year
then
ended,
the
changes
in
its
net
assets
and
its
financial
highlights
for
the
year
ended
June
30,
2023
and
the
period
from
March
22,
2022
(commencement
of
operations)
through
June
30,
2022,
in
conformity
with
U.S.
generally
accepted
accounting
principles.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Trust’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Fund’s
financial
statements
based
on
our
audits.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
(“PCAOB”)
and
are
required
to
be
independent
with
respect
to
the
Trust
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
conducted
our
audits
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audit
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Trust
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
the
Trust’s
internal
control
over
financial
reporting.
As
part
of
our
audits,
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Trust’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audits
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
June
30,
2023,
by
correspondence
with
the
custodian,
brokers
and
others;
when
replies
were
not
received
from
brokers
and
others,
we
performed
other
auditing
procedures.
Our
audits
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
We
believe
that
our
audits
provide
a
reasonable
basis
for
our
opinion.
We
have
served
as
the
auditor
of
one
or
more
investment
companies
in
the
BNY
Mellon
Family
of
Funds
since
at
least
1957,
but
we
are
unable
to
determine
the
specific
year.
New
York,
New
York
August
21,
2023
IMPORTANT
TAX
INFORMATION
(Unaudited)
38
Form
1099-DIV,
Form
1042-S
and
other
year–end
tax
information
provide
shareholders
with
actual
calendar
year
amounts
that
should
be
included
in
their
tax
returns.
Shareholders
should
consult
their
tax
advisers.
The
following
distribution
information
is
being
provided
as
required
by
the
Internal
Revenue
Code
or
to
meet
a
specific
state’s
requirement.
The
fund
designates
the
following
amounts
or,
if
subsequently
determined
to
be
different,
the
maximum
amount
allowable
for
its
fiscal
year
ended June
30,
2023:
For
federal
tax
purposes
the
fund
hereby
reports
67.23%
of
ordinary
income
dividends
paid
during
the
fiscal
year
ended
June
30,
2023 as
qualifying
interest
related
dividends.
INFORMATION
ABOUT
THE
REVIEW
AND
RENEWAL
OF
THE
FUND’S
MANAGEMENT
AND
SUB-INVESTMENT
ADVISORY
AGREEMENTS
(Unaudited)
39
At
a
meeting
held
February
8,
2023,
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended,
evaluated
(i)
a
proposal
to
continue
the
Management
Agreement
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”)
with
respect
to
the
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
(the
“fund”);
and
(ii)
a
proposal
to
continue
the
sub-investment
advisory
agreement
between
the
Adviser
and
Insight
North
America
LLC
(the
“Sub-
Adviser”),
an
affiliate
of
the
Adviser,
on
behalf
of
the
fund
(each
of
the
Management
Agreement
and
the
sub-investment
advisory
agreement,
an
“Agreement,”
and
collectively,
the
“Agreements”).
The
Trustees
also
met
separately
to
consider
the
Agreements.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
To
evaluate
the
Agreements,
the
Board
requested,
and
the
Adviser
and
the
Sub-Adviser
provided,
such
materials
as
the
Board,
with
the
advice
of
counsel,
deemed
reasonably
necessary.
In
addition,
the
Board
considered
information
it
reviewed
at
other
Board
and
Board
committee
meetings.
In
deciding
whether
to
approve
the
Agreements,
the
Board
considered
various
factors,
including
the
(i)
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
Sub-Adviser
under
each
respective
Agreement,
(ii)
investment
performance
of
the
fund,
(iii)
profits
realized
by
the
Adviser
and
its
affiliates
from
its
relationship
with
the
fund,
(iv)
fees
charged
to
comparable
funds,
(v)
other
benefits
to
the
Adviser,
Sub-Adviser
and/or
their
affiliates,
and
(vi)
extent
to
which
economies
of
scale
would
be
shared
as
the
fund
grows.
The
Board
considered
the
Agreements
for
the
fund
and
the
engagement
of
the
Adviser
and
the
Sub-Adviser
separately.
The
Board
reviewed
reports
prepared
by
Broadridge
Financial
Solutions,
Inc.
(“Broadridge”),
an
independent
provider
of
investment
company
data,
which
included
information
(i)
comparing
the
fund’s
performance
with
the
performance
of
a
group
of
other
actively-managed
corporate
bond
exchange
traded
funds
(“ETFs”)
(the
“Performance
Group”)
and
with
a
broader
group
of
retail
and
institutional
corporate
bond
funds
and
ETFs
(the
“Performance
Universe”)
for
the
one-year
period
ended
December
31,
2022;
and
(ii)
comparing
the
fund’s
contractual
management
fees
and
total
expenses
with
a
group
of
other
actively-managed
corporate
bond
ETFs
(the
“Expense
Group”)
and,
with
respect
to
total
expenses,
with
a
broader
group
of
actively-managed
corporate
bond
ETFs
(the
“Expense
Universe”),
the
information
for
which
was
derived
in
part
from
fund
financial
statements
available
to
Broadridge
as
of
the
date
of
its
analysis.
Nature,
Extent
and
Quality
of
Services
The
Board
considered
the
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
the
Sub-Adviser.
In
doing
so,
the
Trustees
relied
on
their
prior
experience
in
overseeing
the
management
of
the
fund
and
the
materials
provided
prior
to
and
at
the
meeting.
The
Board
reviewed
the
Agreements
and
the
Adviser’s
and
the
Sub-Adviser’s
INFORMATION
ABOUT
THE
REVIEW
AND
RENEWAL
OF
THE
FUND’S
MANAGEMENT
AND
SUB-INVESTMENT
ADVISORY
AGREEMENTS
(Unaudited)
(continued)
40
responsibilities
for
managing
investment
operations
of
the
fund
in
accordance
with
the
fund’s
investment
objective
and
policies,
and
applicable
legal
and
regulatory
requirements.
The
Board
appreciated
the
nature
of
the
fund
as
an
exchange-traded
fund
and
considered
the
background
and
experience
of
the
Adviser’s
and
the
Sub-
Adviser’s
senior
management,
including
those
individuals
responsible
for
portfolio
management
and
regulatory
compliance
of
the
funds.
The
Board
also
considered
the
portfolio
management
resources,
structures
and
practices
of
the
Adviser
and
the
Sub-Adviser,
including
those
associated
with
monitoring
and
ensuring
the
fund’s
compliance
with
its
investment
objective
and
policies
and
with
applicable
laws
and
regulations.
The
Board
further
considered
information
about
the
Sub-Adviser’s
best
execution
procedures
as
well
as
the
Adviser’s
and
the
Sub-Adviser’s
overall
investment
management
business.
The
Board
looked
at
the
Adviser’s
general
knowledge
of
the
investment
management
business
and
that
of
its
affiliates,
including
the
Sub-Adviser.
With
respect
to
the
Sub-Adviser,
the
Board
also
considered
the
Adviser’s
favorable
assessment
of
the
nature
and
quality
of
the
services
provided
by
the
Sub-Adviser.
Investment
Performance
The
Board
then
reviewed
the
results
of
the
fund’s
performance
comparisons
and
considered
that
the
fund's
total
return
performance
was
above
the
Performance
Group
and
Performance
Universe
medians
for
the
one-year
period.
Representatives
of
the
Adviser
stated
that
the
usefulness
of
performance
comparisons
may
be
affected
by
a
number
of
factors,
including
different
investment
limitations
and
policies
that
may
be
applicable
to
the
fund
and
comparison
funds
and
the
end
date
selected.
Profits
Realized
by
the
Adviser
The
Board
considered
the
profitability
of
the
advisory
arrangement
with
the
fund
to
the
Adviser
and
its
affiliates.
The
Board
had
the
opportunity
to
discuss
with
representatives
of
the
Adviser
the
process
and
methodology
used
to
calculate
profitability.
Fees
Charged
to
Comparable
Funds
The
Board
evaluated
the
fund’s
unitary
fee
through
review
of
comparative
information
with
respect
to
fees
paid
by
similar
funds
-
i.e.,
other
actively-managed
corporate
bond
ETFs.
The
Board
explored
with
management
the
differences
between
the
fund’s
fee
and
fees
paid
by
similar
funds.
The
Board
noted
the
fund's
contractual
management
fee
was
slightly
higher
than
the
Expense
Group
median
and
the
fund's
total
expenses
were
slightly
higher
than
the
Expense
Group
median
and
the
same
as
the
Expense
Universe
median
total
expenses.
The
Board
considered
the
fee
paid
to
the
Sub-Adviser
in
relation
to
the
fee
paid
to
the
Adviser
by
the
fund
and
the
respective
services
provided
by
the
Sub-Adviser
and
the
Adviser.
The
Board
also
took
into
consideration
that
the
Sub-Adviser's
fee
is
paid
by
the
Adviser
and
not
the
fund.
41
Other
Benefits
The
Board
also
considered
whether
the
Adviser,
the
Sub-Adviser
or
their
affiliates
benefited
in
other
ways
from
their
relationship
with
the
funds,
noting
that
neither
the
Adviser
nor
the
Sub-Adviser
maintains
soft-dollar
arrangements
in
connection
with
the
fund’s
brokerage
transactions.
Economies
of
Scale
The
Board
reviewed
information
regarding
economies
of
scale
or
other
efficiencies
that
may
result
as
the
fund’s
assets
grow
in
size.
The
Board
noted
that
the
advisory
fee
rate
for
the
fund
did
not
provide
for
breakpoints
as
assets
of
the
fund
increases.
The
Adviser
asserted
that
one
of
the
benefits
of
the
unitary
fee
was
to
provide
an
unvarying
expense
structure,
which
could
be
lost
or
diluted
with
the
addition
of
breakpoints.
The
Board
noted
that
it
intends
to
continue
to
monitor
fees
as
the
fund
grows
in
size
and
assess
whether
fee
breakpoints
may
be
warranted.
Conclusion
After
weighing
the
foregoing
factors,
none
of
which
was
dispositive
in
itself
and
may
have
been
weighed
differently
by
each
Trustee,
the
Board
approved
the
continuation
of
the
Agreements
for
the
fund.
In
approving
the
continuance
of
the
Agreements,
the
Board
found
that
the
terms
of
the
Agreements
are
fair
and
reasonable
and
that
the
continuance
of
the
Agreements
are
in
the
best
interests
of
the
fund
and
its
shareholders.
BOARD
MEMBERS
INFORMATION
(Unaudited)
INDEPENDENT
BOARD
MEMBERS
42
J.
Charles
Cardona
(67)
Chairman
of
the
Board
(2020)
Principal
Occupation
During
Past
5
Years:
BNY Mellon
Family of Funds, 
Interested
Director 
(2014
2018), 
Independent Director 
(2019 – Present)
BNY
Mellon
Liquidity
Funds,
Director
(2004
Present)
and
Chairman
(2019
2021)
.
No.
of
Portfolios
for
which
Board
Member
Serves:
39,
including
22
managed
by
an
affiliate
of
the
Adviser
Kristen
M.
Dickey
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Independent
board
director
of
Marstone,
Inc.,
a
financial
technology
company
(since
2018);
Lead
non-executive
director
for
Aperture
Investors,
LLC,
an
investment
management
firm
(since
2018);
Managing
Director—Global
Head
of
Index
Strategy
at
BlackRock,
Inc.
(until
2017)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
F.
Jack
Liebau,
Jr.
(59)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
Director
at
Beach
Investment
Counsel,
a
financial
advisory
firm
(since
2020)
Corporate
director
(since
2015)
Other
Public
Company
Board
Memberships
During
Past
5
Years:
Myers
Industries,
an
industrial
company,
Director
(2015
Present;
Chairman
of
Board
2016
Present)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
Jill
I.
Mavro
(51)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
director
at
CapWGlobal,
LLC,
a
financial
technology
consulting
company
(since
2020)
Founder
and
Principal
of
Spoondrift
Advisory,
LLC
(since
2018);
Senior
Managing
Director,
Head
of
Strategic
Relationships
and
Member
of
SPDR
Executive
Committee
at
State
Street
Global
Advisors
(until
2018)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
43
Kevin
W.
Quinn
(64)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Partner
at
PricewaterhouseCoopers,
LLC
(until
2019)
No.
of
Portfolios
for
which
Board
Member
Serves:
17
Stacy
L.
Schaus
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Chief
Executive
Officer
of
the
Schaus
Group
LLC,
a
consulting
firm
(since
2019);
Advisory
board
member
of
A&P
Capital,
a
consulting
firm
(from
2019-2021);
Executive
Vice
President—Defined
Contribution
Practice
Founder
at
PIMCO
Investment
Management
(until
2018).
No.
of
Portfolios
for
which
Board
Member
Serves:
17
OFFICERS
OF
THE
TRUST
(Unaudited)
44
DAVID
DIPETRILLO,
President
since
February
2020.
Vice
President
and
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2021;
Head
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
February
2023;
Head
of
North
America
Product,
BNY
Mellon
Investment
Management
from
January
2018
to
February
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
103
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
45
years
old
and
has
been
an
employee
of
BNY
Mellon
since
2005. 
PETER
M.
SULLIVAN,
Chief
Legal
Officer
since
July
2021,
Vice
President
and
Assistant
Secretary
since
February
2020.
Chief
Legal
Officer
of
BNY
Mellon
Investment
Adviser,
Inc.
and
Associate
General
Counsel
of
BNY
Mellon
since
July
2021;
Senior
Managing
Counsel
of
BNY
Mellon
from
December
2020
to
July
2021;
and
Managing
Counsel
of
BNY
Mellon
from
March
2009
to
December
2020.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
since
April
2004.
JAMES
WINDELS,
Treasurer
since
February
2020.
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2023;
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
September
2020;
and
Director
BNY
Mellon
Fund
Administration.
 He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
64
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1985.
SARAH
S.
KELLEHER,
Vice
President
and
Secretary
since
February
2020.
Vice
President
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
since
February
2020;
Senior
Managing
Counsel
of
BNY
Mellon
since
September
2021;
and
Managing
Counsel
of
BNY
Mellon
from
December
2017
to
September
2021. 
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
She
is
47
years
old
and
has
been
an
employee
of
BNY
Mellon
since
March
2013.
JAMES
BITETTO,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon
since
December
2019;
Managing
Counsel
of
BNY
Mellon
from
April
2014
to
December
2019;
and
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
December
1996.
DEIRDRE
CUNNANE,
Vice
President
and
Assistant
Secretary
since
February
2020.
Managing
Counsel
of
BNY
Mellon
since
December
2021;
Counsel
of
BNY
Mellon
from
August
2018
to
December
2021;
and
Senior
Regulatory
Specialist
at
BNY
Mellon
Investment
Management
Services
from
February
2016
to
August
2018.
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
32
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
August
2018.
JEFF
PRUSNOFSKY,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
58
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
October
1990.
AMANDA
QUINN,
Vice
President
and
Assistant
Secretary
since
February
2020.
Counsel
of
BNY
Mellon
since
June
2019;
Regulatory
Administration
Manager
at
BNY
Mellon
Investment
Management
Services from
September
2018
to
May
2019;
and
Senior
Regulatory
Specialist
at
BNY
Mellon
Investment
Management
Services
from
April
2015
to
August
2018.
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
45
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
June
2012.
JOANNE
SKERRETT,
Vice
President
and
Assistant
Secretary
since
March
2023.
Managing
Counsel
of
BNY
Mellon
since
June
2022;
and
Senior
Counsel
with
the
Mutual
Fund
Directors
Forum,
a
leading
funds
industry
organization,
from
2016
to
June
2022. 
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
51
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
2022.
DANIEL
GOLDSTEIN,
Vice
President
since
March
2022
Head
of
Product
Development
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023;
and
Senior
Vice
President,
Development
&
Oversight
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
103
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
the
Distributor
since
1991.
JOSEPH
MARTELLA,
Vice
President
since
March
2022
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
December
2022;
Head
of
Product
Management
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023,
and
Senior
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
103
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
46
years
old
and
has
been
an
employee
of
the
Distributor
since
1999.
GAVIN
C.
REILLY,
Assistant
Treasurer
since
February
2020.
Tax
Manager-BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
54
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1991.
ROBERT
SALVIOLO,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
1989.
ROBERT
SVAGNA,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
November
1990.
NATALYA
ZELENSKY,
Vice
President
and
Assistant
Secretary
since
February
2020
and
Chief
Compliance
Officer
since
August
2021.
Chief
Compliance
Officer
since
August
2021
and
Vice
President
since
February
2020
of
BNY
Mellon
ETF
Investment
Adviser,
LLC;
Managing
Counsel
of
BNY
Mellon
from
December
2019
to
August
2021;
Counsel
of
BNY
Mellon
from
May
2016
to
December
2019;
and
Assistant
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
from
April
2018
to
August
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
123
portfolios)
managed
by
the
Adviser or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
May
2016.
CARIDAD
M.
CAROSELLA,
Anti-Money
Laundering
Compliance
Officer
since
February
2020.
Anti-Money
Laundering
Compliance
Officer
of
the
BNY
Mellon
Family
of
Funds
and
BNY
Mellon
Funds
Trust.
She
is
an
officer
of
47
investment
companies
(comprised
of
116
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
54
years
old
and
OFFICERS
OF
THE
TRUST
(Unaudited)
(continued)
46
has
been
an
employee
of
the
Distributor
since
1997.
For
More
Information
2023
BNY
Mellon
Securities
Corporation
4863AR0623
Telephone
Call
your
financial
representative
or
1-833-ETF-BNYM
(383-2696)
(inside
the
U.S.
only)
Mail
BNY
Mellon
ETF
Trust,
240
Greenwich
Street,
New
York,
New
York
10286
E-Mail
Send
your
request
to
info@bnymellon.com
Internet
Information
can
be
viewed
online
or
downloaded
at
www.im.bnymellon.com
BNY
Mellon
ETF
Trust
discloses,
at
www.im.bnymellon.com
,
the
identities
and
quantities
of
the
securities
held
by
the
fund
daily.
The
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
SEC
)
for
the
first
and
third
quarters
of
the
fiscal
year
on
Form
N-PORT.
The
fund
s
Forms
N-PORT
are
available
on
the
SEC
s
website
at
www.sec.gov
.
Additionally,
the
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://im.bnymellon.com/etfliterature
.
The
fund
s
complete
schedule
of
portfolio
holdings,
as
filed
on
Form
N-PORT,
can
also
be
obtained
without
charge,
upon
request,
by
calling
1-833-383-2696.
A
description
of
the
policies
and
procedures
that
the
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
the
fund
voted
these
proxies
for
the
most
recent
12-month
period
ended
June
30
is
available
at
www.im.bnymellon.
com
and
on
the
SEC’s
website
at
www.sec.gov
.
The
description
of
the
policies
and
procedures
is
also
available
without
charge,
upon
request,
by
calling
1-833-383-2696.
BNY
Mellon
ETF
Trust
Custodian
BNY
Mellon
ETF
Investment
Adviser,
LLC
240
Greenwich
Street
New
York,
NY
10286
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Adviser
Transfer
Agent
&
Dividend
Disbursing
Agent
BNY
Mellon
ETF
Investment
Adviser,
LLC
201
Washington
Street
Boston,
MA
02108
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Sub-Adviser
Distributor
Insight
North
America
LLC
200
Park
Avenue,
7th
Floor
New
York,
NY
10166
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
Responsible
Horizons
Corporate
Bond
ETF
RHCB
Item 1. Reports to Stockholders (cont.).
(b)        Not applicable.
Item 2. Code of Ethics.
(a)        As of the period ended June 30, 2023 (the “Reporting Period”), the Registrant has adopted a code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, principal accounting officer, controller or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party.
 
(c)        During the Reporting Period, there have been no amendments to a provision of the code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party, and that relates to any element of the code of ethics description.
 
(d)       During the Reporting Period, the Registrant has not granted any waivers, including an implicit waiver, from a provision of the code of ethics to the Registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party, that relates to one or more of the items set forth in paragraph (b) of this item’s instructions.
 
Item 3. Audit Committee Financial Expert.
The Registrant’s Board of Trustees has determined that Mr. Kevin W. Quinn is qualified to serve as an audit committee financial expert serving on the Registrant’s audit committee and that he is “independent,” as defined by Item 3 of Form N-CSR.
Item 4. Principal Accountant Fees and Services.
(a)        Audit Fees
The aggregate fees billed for each of the last two fiscal years
for professional services rendered by the principal accountant for the audit of the Registrant’s annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements for those fiscal years were $42,450 in 2022 and $43,299 in 2023. 
(b)        Audit-Related Fees
The aggregate fees billed for each of the last two fiscal years for assurance and related services rendered to the Registrant by the principal accountant that are reasonably related to the performance of the audit of the Registrant’s financial statements and are not reported under paragraph (a) of this Item were $12,000 in 2022 and $12,240 in 2023. These services consisted of security counts required by Rule 17f-2 under the Investment Company Act of 1940, as amended.
(c)        Tax Fees
The aggregate fees billed for each of the last two fiscal years for professional services rendered to the Registrant by the principal accountant for tax compliance, tax advice and tax planning were $7600 in 2022 and $7,752 in 2023. These services consisted
of (i) review or preparation of U.S. federal, state, local and excise tax returns; (ii) U.S. federal, state and local entity tax planning, advice and assistance regarding statutory, regulatory or administrative developments, and (iii) tax advice regarding tax qualification
.
(d)       All Other Fees
The aggregate fees billed for each of the last two fiscal years for products and services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item were $0 in 2022 and $0 in 2023.
(e)(1)   Pursuant to the Registrant’s Audit Committee Charter that has been adopted by the audit committee, the audit committee shall approve all audit and permissible non-audit services to be provided to the Registrant and all permissible non-audit services to be provided to its investment adviser or any entity controlling, controlled by or under common control with the investment adviser that provides ongoing services to the Registrant if the engagement relates directly to the operations and financial reporting of the Registrant.
(e)(2)   The percentage of services described in paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, with respect to: Audit-Related Fees was 100%; Tax Fees was 100%; and All Other Fees was 0%. 
(f)        The percentage of hours expended on the principal accountant’s engagement to audit the Registrant’s financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees was less than fifty percent. 
(g)        The aggregate non-audit fees billed by the Registrant’s accountant for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the Registrant for each of the last two fiscal years of the Registrant were $500,896 in 2022 and $269,097 in 2023.
(h)        The Registrant’s audit committee has considered whether the provision of non-audit services that were rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the Registrant that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X is compatible with maintaining the principal accountant’s independence.
(i)         Not applicable.
(j)         Not applicable.
Item 5. Audit Committee of Listed Registrants.
(a)        The Registrant has a separately designated audit committee established in accordance with Section 3(a)(58)(A) of the Securities Exchange Act of 1934, as amended, which consists of independent trustees of the Registrant.  The audit committee members are J. Charles Cardona, Kristen M. Dickey, F. Jack Liebau, Jr., Jill I. Mavro, Kevin W. Quinn, and Stacy L. Schaus.
(b)        Not applicable.
Item 6. Investments.
(a)        The Schedule of Investments in securities of unaffiliated issuers as of the close of the Reporting Period is included as part of the report to shareholders filed under Item 1(a) of this Form N-CSR.
 
(b)        Not applicable.
Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.
Not applicable.
Item 8. Portfolio Managers of Closed-End Management Investment Companies.
Not applicable.
Item 9. Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.
Not applicable.
Item 10. Submission of Matters to a Vote of Security Holders.
There have been no material changes to the procedures by which the shareholders may recommend nominees to the Registrant’s Board of Trustees, where those changes were implemented after the Registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation S‑K (17 CFR 229.407) (as required by Item 22(b)(15) of Schedule 14A (17 CFR 240.14a-101)), or this Item.
 
Item 11. Controls and Procedures.
(a)
  
The Registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the Registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”) (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d-15(b)).
 
(b)
  
There were no changes in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d))) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.
 
Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.
Not applicable.
Item 13. Exhibits.
 
 
(a)(2)(1) Not applicable.
 
(a)(2)(2) Not applicable.
 

SIGNATURES


Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
 
(Registrant)                             BNY Mellon ETF Trust                                             
 
 
By (Signature and Title)*       /s/ David J. DiPetrillo                                                 
                                                David J. DiPetrillo, President
                                                (Principal Executive Officer)
 
Date    08/21/2023                             
 
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
 
 
By (Signature and Title)*       /s/ David J. DiPetrillo                                                 
                                                David J. DiPetrillo, President
                                                (Principal Executive Officer)
 
Date    08/21/2023                             
 
 
By (Signature and Title)*       /s/ James Windels                                                      
                                                James Windels, Treasurer
                                                (Principal Financial and Accounting Officer)
 
Date    08/21/2023                             
 
 
*
Print the name and title of each signing officer under his or her signature.
EX-99.CERT 2 bnymellonetf302.htm
Certification Pursuant to Rule 30a-2(a) under the 1940 Act and
Section 302 of the Sarbanes-Oxley Act of 2002
 
I, David DiPetrillo, certify that:
1.
                 
I have reviewed this report on Form N-CSR of BNY Mellon ETF Trust;
 
2.         Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
 
3.        Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;
 
4.        The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:
 
(a)   Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
 
(b)   Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, 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;
 
(c)   Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and
 
(d)   Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and
 
5.         The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):
 
(a)   All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and
 
(b)   Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.
 
Date:   08/21/2023                                          /s/ David J. DiPetrillo                                     
David J. DiPetrillo
, President
                                                                        (Principal Executive Officer)
 

 

 
Certification Pursuant to Rule 30a-2(a) under the 1940 Act and
Section 302 of the Sarbanes-Oxley Act of 2002
 
I, James Windels, certify that:
1.         I have reviewed this report on Form N-CSR of BNY Mellon ETF Trust;
 
2.         Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
 
3.         Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;
 
4.         The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:
 
(a)  Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
 
(b)  Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, 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;
 
(c)  Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and
 
(d) Disclosed in this report any change in the registrant's internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant's internal control over financial reporting; and
 
5.         The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):
 
(a)  All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and
 
(b)  Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.
 
Date:   08/21/2023                                          /s/ James Windels                              
                                                                        James Windels, Treasurer
                                                                        (Principal Financial and Accounting Officer)
 
EX-99.906 CERT 3 bnymellonetf906.htm
Certification Pursuant to Rule 30a-2(b) under the 1940 Act and
Section 906 of the Sarbanes-Oxley Act of 2002
 
 
 
Each of the undersigned hereby certifies that:
 
 
1.      The Form N-CSR of BNY Mellon ETF Trust (the “Report”) fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and
 
2.      The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of BNY Mellon ETF Trust.
 
 
 
Date:   08/21/2023                                          /s/ David J. DiPetrillo                                     
David J. DiPetrillo
, President
                                                                        (Principal Executive Officer)
 
 
 
 
Date:   08/21/2023                                          /s/ James Windels                                          
                                                                        James Windels, Treasurer
                                                                        (Principal Financial and Accounting Officer)
 
 
EX-99.CODE ETH 4 ncsrcodeofethicsjan2022.htm
Sarbanes-Oxley Code of Ethics for Principal Executive, Financial and Accounting Officers
Most Recently Revised:  January 2022 
_____________________________________________________________________________________

Background

In accordance with the Sarbanes-Oxley Act of 2002 (the “SOX Act”) and the rules promulgated thereunder by the SEC, a RIC is required to file, on a semi-annual basis, a report on Form N-CSR in which the RIC must disclose whether it has adopted, for the purposes set forth below, a code of ethics applicable to certain of its officers.
Such a code of ethics will govern the conduct of a RIC’s principal executive officer, the principal financial officer, the principal accounting officer or controller or persons performing similar functions (each a “Covered Officer” and collectively, “Covered Officers”), regardless of whether such persons are employed by the RIC or a third party for the purpose of promoting:
o
       
Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
o
       
Full, fair, accurate, timely, and understandable disclosure in reports and documents that a RIC files with, or submits to, the SEC and in other public communications by the RIC;
o
       
Compliance with applicable governmental laws, rules and regulations;
o
       
The prompt internal reporting of violations of the code of ethics to the appropriate persons as set forth in the code of ethics; and
o
       
Accountability for adherence to the code of ethics.
o
       
Each Covered Officer should adhere to a high standard of business ethics and should be sensitive to situations that may give rise to actual as well as apparent conflicts of interest. All Covered Officers must become familiar and fully comply with the code of ethics.

Policies and Procedures

Conflicts of Interest

A “conflict of interest” occurs when a Covered Officer’s private interest interferes with the interests of, or his or her service to, the Funds. For example, a conflict of interest would arise if a Covered Officer receives improper personal benefits as a result of his or her position with the Funds.
 
Certain conflicts of interest may arise out of the relationships between Covered Officers and the Funds and already are subject to conflict of interest provisions in the IC Act and the Advisers Act. For example, Covered Officers may not individually engage in certain transactions (such as the purchase or sale of securities or other property) with the Funds because of their status as “affiliated persons” of a Fund. Each Fund and certain of its Service Providers’ compliance programs and procedures are designed to prevent, or identify and correct, violations of these provisions. This code of ethics does not, and is not intended to, repeat or replace these programs and procedures, and such conflicts fall outside the parameters of this code of ethics. Rather, this code of ethics (the “SOX Code”) is intended to address the Covered Officers’ obligations under the SOX Act.
 
Although typically not presenting an opportunity for improper personal benefit, conflicts may arise from, or as a result of, the contractual relationship between the Funds and their investment adviser, principal underwriter, or administrator (each an “Employer”) of which the Covered Officers may be officers or employees. As a result, this SOX Code recognizes that the Covered Officers will, in the normal course of their duties (whether for the Funds or an Employer), be involved in establishing policies and implementing decisions that will have different effects on the Employer and the Funds. The participation of the Covered Officers in such activities is inherent in the contractual relationships between the Funds and the Employers and is consistent with the performance by the Covered Officers of their duties as officers of the Funds. Thus, if performed in conformity with the provisions of the IC Act and the Advisers Act, such activities normally will be deemed to have been handled ethically. In addition, it is recognized by the Board that the Covered Officers may also be officers or employees of one or more other investment companies covered by this SOX Code or other codes of ethics.
 
Other conflicts of interest are covered by the SOX Code, even if such conflicts of interest are not subject to provisions in the IC Act and the Advisers Act. While it is impossible to describe all conflicts that may arise, a conflict should be considered to exist whenever a Covered Officer participates, directly or indirectly, in any material investment, interest, association, activity or relationship that a reasonable observer would view as likely to impair the Covered Officer’s objectivity. Disclosure of conflicts should be made to the CCO or other appropriate senior executive or to a member of the Board. Covered Officers that are unsure whether a particular fact pattern gives rise to a conflict of interest or whether a particular transaction or relationship is “material” should bring such matter to the attention of the CCO.

Disclosure Documents and Compliance

Covered Officers must not knowingly make any misrepresentations regarding the Funds’ financial statements or any facts in the preparation of the Funds’ financial statements, and must comply with all applicable laws, standards, principles, guidelines, rules and regulations in the preparation of the Funds’ financial statements. This section is intended to prohibit an officer from knowingly:
 
  • Making, or permitting or directing another to make, materially false or misleading entries in the Funds’ financial statements or records;
 
  • Failing to correct the Funds’ financial statements or records that are materially false or misleading when he or she has the authority to record an entry; and
 
  • Signing, or permitting or directing another to sign, a document containing materially false or misleading financial information.
 
Each Covered Officer:
 
  • Should familiarize himself or herself with the disclosure requirements generally applicable to the Funds;
 
  • Should not knowingly misrepresent, or cause others to misrepresent, facts about the Funds to others, including to the Board, auditors, governmental regulators or self-regulatory organizations;
 
  • Should promote full, fair, accurate, timely and understandable disclosure in the reports and documents the Funds file with, or submit to, the SEC and in other public communications made by the Funds; and
 
  • Has the responsibility to promote compliance with the standards and restrictions imposed by applicable laws, rules and regulations.

Reporting of Violations and Sanctions

Covered Officers should promptly report any conduct or actions by themselves or another Covered Officer that do not comply or otherwise violate this SOX Code to the CCO. The CCO is charged with investigating any allegation and will report his or her findings and recommendations to the Board’s Audit Committee. If the Audit Committee concludes that the Covered Officer has violated this SOX Code, it may impose appropriate sanctions, including:
 
  • A reprimand;
  • Disgorgement of any profit or restitution of any loss;
  • Imposition of additional controls and procedures;
  • Suspension;
  • Termination; and
  • Any other measure that the Audit Committee may decide is appropriate under the circumstances, including notifying regulatory authorities.
 
Any matter that the Audit Committee believes is a material violation will be promptly reported to the Board.
 
A Covered Officer must not retaliate against any other Covered Officer or any employee or agent of an affiliated person of the Funds for good faith reports of potential violations.

Accountability of Covered Officers

Each Covered Officer must:
 
  • Upon adoption of the SOX Code (or thereafter as applicable, upon becoming a Covered Officer), affirm in writing to the Board that he or she has received, read, and understands the SOX Code; and
 
  • Annually thereafter affirm to the Board that he or she has complied with the requirements of the SOX Code.

Other Policies and Procedures

This SOX Code shall be the sole code of ethics adopted by the Funds for purposes of Section 406 of the SOX Act and the rules and forms applicable to RICs thereunder. Insofar as other policies or procedures of the Funds, the Employers or other Service Providers govern or purport to govern the behavior or activities of the Covered Officers who are subject to this SOX Code, they are superseded by this SOX Code to the extent that they overlap or conflict with the provisions of this SOX Code. The Funds and any Employer code of ethics under Rule 17j-1 under the IC Act are separate requirements applying to the Covered Officers and others, and are not part of this SOX Code.

Amendments

The Board may from time to time amend this SOX Code or adopt such interpretations of this SOX Code as they deem appropriate. Any amendments to this SOX Code will be provided to the Covered Officers.

Internal Use and Confidentiality

All reports and records prepared or maintained pursuant to this SOX Code shall be treated as confidential and shall not be disclosed to anyone other than the Board, the Covered Officers and Fund Counsel, except as otherwise requested in accordance with applicable law.
 
The SOX Code is intended solely for the internal use by the Funds and does not constitute an admission, by or on behalf of the Funds, as to any fact, circumstance, or legal conclusion.

 

                  
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(OFFICER NAME), in his/her capacity as a Covered Officer under the Sarbanes-Oxley Code of Ethics for Principal Executive, Financial and Accounting Officers (the "Code") adopted by the funds in the BNY Mellon ETF Trust (the "Trust"), does hereby affirm to the Board of Trustees of the Trust that he/she has complied with the requirements of the Code during (YEAR).
 
 
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