0001752724-20-070739.txt : 20200415
0001752724-20-070739.hdr.sgml : 20200415
20200415134953
ACCESSION NUMBER: 0001752724-20-070739
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 2
CONFORMED PERIOD OF REPORT: 20200131
FILED AS OF DATE: 20200415
DATE AS OF CHANGE: 20200415
EFFECTIVENESS DATE: 20200415
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Arrow ETF Trust
CENTRAL INDEX KEY: 0001532206
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FILING VALUES:
FORM TYPE: N-CEN
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-22624
FILM NUMBER: 20793277
BUSINESS ADDRESS:
STREET 1: 17605 WRIGHT STREET
CITY: OMAHA
STATE: NE
ZIP: 68130
BUSINESS PHONE: 631-470-2600
MAIL ADDRESS:
STREET 1: 17605 WRIGHT STREET
CITY: OMAHA
STATE: NE
ZIP: 68130
FORMER COMPANY:
FORMER CONFORMED NAME: Northern Lights ETF Trust
DATE OF NAME CHANGE: 20111007
0001532206
S000035751
Arrow Dow Jones Global Yield ETF
C000109586
Arrow Dow Jones Global Yield ETF
GYLD
N-CEN
1
primary_doc.xml
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ARROW ETF TRUST
811-22624
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6100 Chevy Chase Drive Suite 100
Laurel
20707
US-MD
US
1-877-277-6933
Gemini Fund Services
4221 North 203rd Street, Suite 100
Elkhorn
68022-3474
631-470-2600
Fund Accounting and Transfer Agent Records
N
N
N
N-1A
1
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Robert S Andrialis
N/A
N
Thomas T. Sarkany
N/A
N
Paul Montgomery
N/A
N
Joseph Barrato
N/A
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Fit Compliance
N/A
6219 29th Street N.
Arlington
22207
XXXXXX
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N
N
N
N
N
Northern Lights Distributors, LLC
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N/A
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BBD, LLP
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Arrow Dow Jones Global Yield ETF
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N/A
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Rule 17a-7 (17 CFR 270.17a-7)
Rule 12d1-1 (17 CFR 270.12d1-1)
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Arrow Investment Advisors, LLC
811-22638
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5493000XQEYNVZTQTG53
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Brown Brothers Harriman & Co.
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N/A
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ICE Data Services
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GTS MISCHLER
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N/A
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BARRINGTON RESEARCH
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JANE STREET
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BARCLAYS
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JONES TRADING
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Brown Brothers Harriman & Co
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MARKETAXESS
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PERSHING LLC
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CREDIT SUISSE
N/A
N/A
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MIRAE ASSET
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INTERNAL CONTROL RPT
2
GYLD_NCEN_letter.txt
ARROW GYLD IC LETTER
REPORT OF INDEPENDENT REGISTERED
PUBLIC ACCOUNTING FIRM
To the Board of Trustees of Arrow ETF Trust
and the Shareholders of Arrow Dow Jones Global
Yield ETF
In planning and performing our audit of the financial
statements of Arrow Dow Jones Global Yield ETF, a
series of shares of beneficial interest in Arrow ETF
Trust (the "Fund"), as of January 31, 2020, and for
the year then ended, in accordance with the
standards of the Public Company Accounting
Oversight Board (United States) ("PCAOB"), we
considered the Funds internal control over financial
reporting, including controls over safeguarding
securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion
on the financial statements and to comply with the
requirements of Form N-CEN, but not for the purpose
of expressing an opinion on the effectiveness of the
Funds internal control over financial reporting.
Accordingly, we express no such opinion.
The management of the Fund is responsible for
establishing and maintaining effective internal control
over financial reporting. In fulfilling this responsibility,
estimates and judgments by management are
required to assess the expected benefits and related
costs of controls. A funds internal control over
financial reporting is a process designed to provide
reasonable assurance regarding the reliability of
financial reporting and the preparation of financial
statements for external purposes in accordance with
accounting principles generally accepted in the United
States of America ("GAAP"). A funds internal control
over financial reporting includes those policies and
procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the assets
of the fund; (2) provide reasonable assurance that
transactions are recorded as necessary to permit
preparation of the financial statements in accordance
with GAAP, and that receipts and expenditures of the
fund are being made only in accordance with
authorizations of management and trustees of the
fund; and (3) provide reasonable assurance regarding
prevention or timely detection of unauthorized
acquisition, use or disposition of a funds assets that
could have a material effect on the financial
statements.
Because of inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk
that controls may become inadequate because of
changes in conditions or that the degree of
compliance with the policies or procedures may
deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does
not allow management or employees, in the normal
course of performing their assigned functions, to
prevent or detect misstatements on a timely basis. A
material weakness is a deficiency, or combination of
deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility
that a material misstatement of the Funds annual or
interim financial statements will not be prevented or
detected on a timely basis.
Our consideration of the Funds internal control over
financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal control
that might be material weaknesses under standards
established by the PCAOB. However, we noted no
deficiencies in the Funds internal control over
financial reporting and its operation, including controls
over safeguarding securities, that we consider to be a
material weakness, as defined above, as of January
31, 2020.
This report is intended solely for the information and
use of management and the shareholders of Arrow
Dow Jones Global Yield ETF, the Board of Trustees
of Arrow ETF Trust and the Securities and Exchange
Commission and is not intended to be and should not
be used by anyone other than these specified parties.
BBD, LLP
Philadelphia, Pennsylvania
March 31, 2020