EXEMPT ORDER INFO

Each series of the Trust operates as an exchange traded fund. As a result, each Trust is heavily reliant on exemptive relief under the Act and the Exchange Act. Noted below are the exemptive orders that the Trust relies upon, or in the case of exemptive relief from Section 12(d)(1) will rely upon if the facts warrant it. Exemptive relief of general applicability to ETFs as a class, but not expressly issued to the Trust, is not included.

1. Investment Company Act Release No. 32025 (March 8, 2016) (relief for “Self-Indexing Trust”);

2. Investment Company Act Release No. 27743 (February 27, 2007) (relief allowing investment companies to acquire shares of the Funds in excess of the limitations of Section 12(d)(1));

3. Investment Company Act Release No. 28813 (July 7, 2009) (relief permitting Fund of Funds relying on Section 12(d)(1)(G) to invest in “other investments”);

4. Investment Company Act Release No. 30238 (October 23, 2012) (relief allowing the Funds to invest in registered investment companies in excess of the limitations imposed by Sections 12(d)(1) )(“2012 Order”); and

5. Investment Company Act Release No. 32035 (March 22, 2016) (amending 2012 Order to also permit investments in business development companies).

OTHER REQUIRED INFO

Invesco Defensive Equity ETF, Invesco Multi-Factor Large Cap ETF and Invesco U.S. Large Cap Optimized Volatility ETF (“The Funds”) commenced operations (the “Commencement Date”) on April 6, 2018 as a result of a reorganization approved by shareholders at a special meeting held on February 16, 2018, or at a subsequent adjournment of the special meeting. The Funds acquired all, or substantially all, of the assets and all of the stated liabilities included in the financial statements of corresponding predecessor funds (the “Predecessor Funds”). Prior to the close of business on its respective Commencement Date, each Predecessor Fund was a separate series of an unaffiliated investment company. Information presented herein prior to the Commencement Date includes information with respect to the Predecessor Funds, except that Predecessor Fund information is not reflected herein to the extent such information is not available to the Funds.

INTERNAL CONTROL RPT

Report of Independent Registered Public Accounting Firm

To the Board of Trustees of Invesco Exchange-Traded Self-Indexed Fund Trust and Shareholders of each of the thirty-one funds listed in Appendix A

In planning and performing our audit of the financial statements of each of the thirty-one funds listed in Appendix A (thirty-one of the funds constituting Invesco Exchange-Traded Self-Indexed Fund Trust, referred to hereafter as the “Funds”) as of and for each of the periods indicated in Appendix A, 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 do not express an opinion on the effectiveness of the Funds’ internal control over financial reporting.

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

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

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

Our consideration of the 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 over financial reporting 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 their operation, including controls over safeguarding securities, that we consider to be material weaknesses as defined above as of August 31, 2018.

This report is intended solely for the information and use of the Board of Trustees of Invesco Exchange-Traded Self-Indexed Fund 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.

/s/ PricewaterhouseCoopers LLP

Chicago, Illinois

October 26, 2018

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Appendix A

Fund Name
Invesco BulletShares 2018 Corporate Bond ETF	(a)
Invesco BulletShares 2018 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2019 Corporate Bond ETF	(a)
Invesco BulletShares 2019 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2020 Corporate Bond ETF	(a)
Invesco BulletShares 2020 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2021 Corporate Bond ETF	(a)
Invesco BulletShares 2021 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2022 Corporate Bond ETF	(a)
Invesco BulletShares 2022 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2023 Corporate Bond ETF	(a)
Invesco BulletShares 2023 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2024 Corporate Bond ETF	(a)
Invesco BulletShares 2024 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2025 Corporate Bond ETF	(a)
Invesco BulletShares 2025 High Yield Corporate Bond ETF	(a)
Invesco BulletShares 2026 Corporate Bond ETF	(a)
Invesco BulletShares 2027 Corporate Bond ETF	(a)
Invesco BulletShares 2026 High Yield Corporate Bond ETF	(b)
Invesco BulletShares 2028 Corporate Bond ETF	(b)
Invesco Corporate Income Defensive ETF	(c)
Invesco Corporate Income Value ETF	(c)
Invesco Emerging Markets Debt Defensive ETF	(c)
Invesco Emerging Markets Debt Value ETF	(c)
Invesco Investment Grade Defensive ETF	(c)
Invesco Investment Grade Value ETF	(c)
Invesco Multi-Factor Core Fixed Income ETF	(c)
Invesco Multi-Factor Core Plus Fixed Income ETF	(c)
Invesco Multi-Factor Large Cap ETF	(d)
Invesco Defensive Equity ETF	(e)
Invesco U.S. Large Cap Optimized Volatility ETF	(e)

(a) For the period June 1, 2018 through August 31, 2018

(b) For the period August 7, 2018 through August 31, 2018

(c) For the period July 23, 2018 through August 31, 2018

(d) For the period November 1, 2018 through August 31, 2018

(e) For the year ended August 31, 2018

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