0001145549-21-006815.txt : 20210216 0001145549-21-006815.hdr.sgml : 20210216 20210216100228 ACCESSION NUMBER: 0001145549-21-006815 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 4 CONFORMED PERIOD OF REPORT: 20201130 FILED AS OF DATE: 20210216 DATE AS OF CHANGE: 20210216 EFFECTIVENESS DATE: 20210216 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Tidal ETF Trust CENTRAL INDEX KEY: 0001742912 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-23377 FILM NUMBER: 21633750 BUSINESS ADDRESS: STREET 1: 898 N BROADWAY, SUITE 2 CITY: MASSAPEQUA STATE: NY ZIP: 11758 BUSINESS PHONE: 844-986-7676 MAIL ADDRESS: STREET 1: 898 N BROADWAY, SUITE 2 CITY: MASSAPEQUA STATE: NY ZIP: 11758 0001742912 S000063572 Aware Ultra-Short Duration Enhanced Income ETF C000205986 Aware Ultra-Short Duration Enhanced Income ETF AWTM 0001742912 S000066941 RPAR Risk Parity ETF C000215408 RPAR Risk Parity ETF RPAR 0001742912 S000067282 SP Funds Dow Jones Global Sukuk ETF C000216394 SP Funds Dow Jones Global Sukuk ETF SPSK 0001742912 S000067283 SP Funds S&P 500 Sharia Industry Exclusions ETF C000216395 SP Funds S&P 500 Sharia Industry Exclusions ETF SPUS N-CEN 1 primary_doc.xml X0303 N-CEN LIVE 0001742912 XXXXXXXX false false false N-1A S000063572 C000205986 S000066941 C000215408 S000067283 C000216395 S000067282 C000216394 Tidal ETF Trust 811-23377 0001742912 549300VTYHP8U2332C46 c/o Tidal ETF Services, LLC 898 N. Broadway, Suite 2 Massaqequa 11758 US-NY US 8449867676 U.S. Bancorp Fund Services LLC 615 East Michigan St. Milwaukee 53202 18336121912 Maintain physical/electronic accounts/books or any document required by section 31(a) of the Act (15 U.S.C. 80a-30(a)) and the rules under that section. N N N N-1A 11 Y Dusko Culafic N/A N Eduardo Mendoza N/A N Mark H.W. Baltimore N/A N Ian C. Carroll N/A Y Eric W. Falkeis N/A Y Bridget P. Garcia N/A c/o Cipperman Compliance Services, LLC 480 E. Swedesford Road, Suite 220 Wayne 19087 XXXXXX N N N N N N Foreside Fund Services, LLC 8-51293 000046106 N/A N N Tait Weller and Baker LLP 00445 N/A N N N N N N Aware Ultra-Short Duration Enhanced Income ETF S000063572 549300Q6OV7D12QB4045 N 1 0 0 Exchange-Traded Fund N N N N N/A N/A N/A N/A N N N N Toroso Investments, LLC 801-76857 000164201 N/A N Aware Asset Management, Inc. 801-111803 000286557 25490092K87SPH11PQ85 N N U.S. Bancorp Fund Services LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N Intercontinental Exchange Inc. 5493000F4ZO33MV32P92 N PricingDirect Inc. 549300WIC0TOJ7N7GD54 N Bloomberg L.P. 549300B56MD0ZC402L06 N Thomson Reuters Pricing Service N/A CA N IHS Markit Ltd. 549300HLPTRASHS0E726 BM N Standard and Poors Financial Services LLC 549300U4VWNITEKO2881 N N U.S. Bank N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) Euroclear Bank SA/NV 549300OZ46BRLZ8Y6F65 BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) N N Tidal ETF Servcies, LLC N/A Y N U.S. Bancorp Global Fund Services LLC N1GZ7BBF3NP8GI976H15 N Y N 0.000000000000 J.P. Morgan Securities, LLC 8-35008 000000079 ZBUT11V806EZRVTWT807 389064591.700000000000 Deutsche Bank Securities, Inc. 8-17822 000002525 9J6MBOOO7BECTDTUZW19 49622966.260000000000 Wells Fargo Securities, LLC 8-65876 000126292 VYVVCKR63DVZZN70PB21 195161308.840000000000 Barclays Capital, Inc. 8-41342 000019714 AC28XWWI3WIBK2824319 100588320.630000000000 Cowen and Company, LLC 8-22522 000007616 549300WR155U7DVMIW58 98296245.030000000000 Goldman Sachs & Co., LLC 8-12900 000000361 FOR8UP27PHTHYVLBNG30 74659014.780000000000 Morgan Stanley & Co., LLC 8-15869 000008209 9R7GPTSO7KV3UQJZQ078 74650437.810000000000 MarketAxess Corporation 8-50727 000044542 GPSMMRI21JE7ZCVYF972 72749629.660000000000 Pershing LLC 8-17574 000007560 ZI8Q1A8EI8LQFJNM0D94 64960727.590000000000 Citigroup Global Markets, Inc. 8-8177 000007059 MBNUM2BPBDO7JBLYG310 52282455.470000000000 1340155973.130000000000 N 337492389.993000000000 Uncommitted 10000000.000000000000 N N N N RPAR Risk Parity ETF S000066941 549300P6SPNYGRUISQ43 Y 1 0 0 Exchange-Traded Fund Y N N N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Y Y N N Toroso Investments, LLC 801-76857 000164201 N/A N U.S. Bancorp Fund Services LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N Intercontinental Exchange Inc. 5493000F4ZO33MV32P92 N PricingDirect Inc. 549300WIC0TOJ7N7GD54 N Bloomberg L.P. 549300B56MD0ZC402L06 N Thomson Reuters Pricing Service N/A CA N IHS Markit Ltd. 549300HLPTRASHS0E726 BM N Standard and Poors Financial Services LLC 549300U4VWNITEKO2881 N N U.S. Bank N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) BNP Paribas Securities Services (BNP) 549300WCGB70D06XZS54 GB N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) The Bank of New York Mellon HPFHU0OQ28E4N0NFVK49 N Y Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) Euroclear Bank SA/NV 549300OZ46BRLZ8Y6F65 BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) Royal Bank of Canada ES7IP3U3RHIGC71XBU11 CA N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) Svenska Handelsbanken AB (publ), Denmark Branch NHBDILHZTYCNBV5UYZ31 DK N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) Svenska Handelsbanken AB (publ), Norway Branch NHBDILHZTYCNBV5UYZ31 NO N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) Svenska Handelsbanken AB (publ), Sweden Branch NHBDILHZTYCNBV5UYZ31 SE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) N N Tidal ETF Servcies, LLC N/A Y N U.S. Bancorp Global Fund Services LLC N1GZ7BBF3NP8GI976H15 N Y N BTIG, LLC 8-65473 000122225 549300GTG9PL6WO3EC51 165955.790000000000 Mischler Financial Group, Inc. 8-48067 000037818 2549004IPXPSM9EJFC92 32821.990000000000 World Equity Group, Inc. 8-44088 000029087 N/A 22937.970000000000 Robert W. Baird & Co., Inc. 8-497 000008158 549300772UJAHRD6LO53 2507.590000000000 Jane Street Execution Services, LLC 8-69254 000167280 549300HXJLXCPDWAH070 2433.810000000000 Wallachbeth Capital, LLC 8-67936 000147853 549300R371KUKXEXC133 2113.020000000000 Wolverine Execution Services, LLC 8-65336 000120719 N/A 1035.800000000000 Virtu Americas, LLC 8-68193 000149823 549300RA02N3BNSWBV74 131.300000000000 229937.270000000000 U.S. Bancorp Investments, Inc. 8-35359 000017868 H85Z6XZP8B10ES0M2G89 329828335.860000000000 Jane Street Execution Services, LLC 8-69254 000167280 549300HXJLXCPDWAH070 235318140.720000000000 BTIG, LLC 8-65473 000122225 549300GTG9PL6WO3EC51 12538.800000000000 565159015.380000000000 N 460088975.456299000000 N N N N SP Funds S&P 500 Sharia Industry Exclusions ETF S000067283 549300JL4D4SLC04BO54 Y 1 0 0 Exchange-Traded Fund N N 0.235420212828 -0.370911712414 1.050152191759 1.050129865658 Y N N N N/A N/A N/A N/A N N N N Toroso Investments, LLC 801-76857 000164201 N/A N ShariaPortfolio, Inc. 801-80652 000173937 N/A N N U.S. Bancorp Fund Services LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N Intercontinental Exchange Inc. 5493000F4ZO33MV32P92 N PricingDirect Inc. 549300WIC0TOJ7N7GD54 N Bloomberg L.P. 549300B56MD0ZC402L06 N Thomson Reuters Pricing Service N/A CA N IHS Markit Ltd. 549300HLPTRASHS0E726 BM N Standard and Poors Financial Services LLC 549300U4VWNITEKO2881 N N U.S. Bank N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N N Tidal ETF Servcies, LLC N/A Y N U.S. Bancorp Global Fund Services LLC N1GZ7BBF3NP8GI976H15 N Y N BTIG, LLC 8-65473 000122225 549300GTG9PL6WO3EC51 1659.970000000000 Wallachbeth Capital, LLC 8-67936 000147853 549300R371KUKXEXC133 228.770000000000 World Equity Group, Inc. 8-44088 000029087 N/A 7.200000000000 1895.940000000000 0.000000000000 N 23350125.622000000000 N N N N SP Funds Dow Jones Global Sukuk ETF S000067282 549300T032UNSH1TQQ47 Y 1 0 0 Exchange-Traded Fund N N -3.255914227188 -3.931563031051 1.960318287604 1.960309774015 Y N N N N/A N/A N/A N/A N N N N Toroso Investments, LLC 801-76857 000164201 N/A N ShariaPortfolio, Inc. 801-80652 000173937 N/A N N U.S. Bancorp Fund Services LLC 85-11357 N1GZ7BBF3NP8GI976H15 N N N Intercontinental Exchange Inc. 5493000F4ZO33MV32P92 N PricingDirect Inc. 549300WIC0TOJ7N7GD54 N Bloomberg L.P. 549300B56MD0ZC402L06 N Thomson Reuters Pricing Service N/A CA N IHS Markit Ltd. 549300HLPTRASHS0E726 BM N Standard and Poors Financial Services LLC 549300U4VWNITEKO2881 N N U.S. Bank N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) Euroclear Bank SA/NV 549300OZ46BRLZ8Y6F65 BE N Y Foreign custodian - rule 17f-5 (17 CFR 270.17f-5) N N Tidal ETF Servcies, LLC N/A Y N U.S. Bancorp Global Fund Services LLC N1GZ7BBF3NP8GI976H15 N Y N 0.000000000000 Flow Traders U.S. LLC 8-68300 000150780 549300K64LZQW7R9ST34 21541803.600000000000 World Equity Group, Inc. 8-44088 000029087 N/A 15677033.200000000000 37218836.800000000000 N 21357641.130000000000 N N N N SP Funds Dow Jones Global Sukuk ETF S000067282 N 25000.000000000000 100.000000000000 0.000000000000 0.000000000000 0.000000000000 100.000000000000 0.000000000000 0.000000000000 0.000000000000 0 500 0 0 500 0 0 500 0 0 500 0 N SP Funds S&P 500 Sharia Industry Exclusions ETF S000067283 N 25000.000000000000 2.840000000000 0.842090000000 97.160000000000 0.842090000000 3.300000000000 0.098690000000 96.700000000000 0.098690000000 0 500 0 0 500 0 0 500 0 0 500 0 Y RPAR Risk Parity ETF S000066941 N 25000.000000000000 53.070000000000 6.570000000000 46.930000000000 6.570000000000 0.550000000000 0.387850000000 99.450000000000 0.387850000000 0 1000 0 0 1000 0 0 1000 0 0 1000 0 Y Aware Ultra-Short Duration Enhanced Income ETF S000063572 N 25000.000000000000 100.000000000000 0.000000000000 0.000000000000 0.000000000000 100.000000000000 0.000000000000 0.000000000000 0.000000000000 0 250 0 0 250 0 0 250 0 0 250 0 N true INTERNAL CONTROL RPT 2 aware_acctlttr.htm AWARE ETF INTERNAL CONTROL LETTER



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


Board of Trustees of Tidal ETF Trust and
Shareholders of Aware Ultra-Short Duration Enhanced Income ETF
Massapequa, New York


In planning and performing our audit of the financial statements of Aware Ultra-Short Enhanced Income ETF, a series of shares of Tidal ETF Trust (the “Fund”) as of and for the year ended November 30, 2020, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered their internal control over financial reporting, including control activities for safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting.   In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.   A company’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 company’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 company; (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 company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company’s 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 company’s annual or interim financial statements will not be prevented or detected on a timely basis.




Board of Trustees of Tidal ETF Trust and
Shareholders of Aware Ultra-Short Duration Enhanced Income ETF
Page Two


Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be significant deficiencies or material weaknesses under standards established by the Public Company Accounting Oversight Board (United States).   However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of November 30, 2020.

This report is intended solely for the information and use of management, Shareholders and Board of Trustees of Tidal 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.



/s/ TAIT, WELLER & BAKER LLP

Philadelphia, Pennsylvania
January 29, 2021




INTERNAL CONTROL RPT 3 rpar_acctlttr.htm RPAR ETF INTERNAL CONTROL LETTER



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


Board of Trustees of Tidal ETF Trust and
Shareholders of RPAR Risk Parity ETF
Massapequa, New York


In planning and performing our audit of the financial statements of RPAR Risk Parity ETF, a series of shares of Tidal ETF Trust (the “Fund”) as of and for the period ended November 30, 2020, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered their internal control over financial reporting, including control activities for safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting.   In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.   A company’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 company’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 company; (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 company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company’s 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 company’s annual or interim financial statements will not be prevented or detected on a timely basis.



Board of Trustees of Tidal ETF Trust and
Shareholders of RPAR Risk Parity ETF
Page Two


Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be significant deficiencies or material weaknesses under standards established by the Public Company Accounting Oversight Board (United States).   However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of November 30, 2020.

This report is intended solely for the information and use of management, Shareholders and Board of Trustees of Tidal 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.


/s/ TAIT, WELLER & BAKER LLP

Philadelphia, Pennsylvania
January 29, 2021




INTERNAL CONTROL RPT 4 spfunds_acctlttr.htm SP FUNDS INTERNAL CONTROL REPORT



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


Board of Trustees of Tidal ETF Trust and
Shareholders of SP Funds S&P 500 Sharia Industry Exclusions ETF and
SP Funds Dow Jones Global Sukuk ETF
Massapequa, New York


In planning and performing our audit of the financial statements of SP Funds S&P 500 Sharia Industry Exclusions ETF and SP Funds Dow Jones Global Sukuk ETF, each a series of shares of Tidal ETF Trust (the “Funds”) as of and for the period ended November 30, 2020, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered their internal control over financial reporting, including control activities for safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds’ internal control over financial reporting. Accordingly, we express no such opinion.

The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting.   In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.   A company’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 company’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 company; (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 company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company’s 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 company’s annual or interim financial statements will not be prevented or detected on a timely basis.




Board of Trustees of Tidal ETF Trust and
Shareholders of SP Funds S&P 500 Sharia Industry Exclusions ETF and
SP Funds Dow Jones Global Sukuk ETF
Page Two


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 significant deficiencies or material weaknesses under standards established by the Public Company Accounting Oversight Board (United States).   However, we noted no deficiencies in the Funds’ internal control over financial reporting and its operation, including controls for safeguarding securities, which we consider to be material weaknesses, as defined above, as of November 30, 2020.

This report is intended solely for the information and use of management, Shareholders and Board of Trustees of Tidal 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.


/s/ TAIT, WELLER & BAKER LLP

Philadelphia, Pennsylvania
January 29, 2021