COVER 7 filename7.htm SEC Transmittal Letter

 

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SIDLEY AUSTIN LLP

 

787 SEVENTH AVENUE

 

NEW YORK, NY 10019

 

+1 212 839 5300

 

+1 212 839 5599 FAX

 

AMERICA • ASIA PACIFIC • EUROPE

  

January 7, 2021

VIA ELECTRONIC FILING

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 

  Re:

BlackRock U.S. Carbon Transition Readiness ETF and BlackRock World

    

ex U.S. Carbon Transition Readiness ETF, each a series of BlackRock ETF Trust

    

Post-Effective Amendment No. 17 to the Registration Statement

    

on Form N-1A (File  Nos. 333-228832 and 811-23402)                                             

Ladies and Gentlemen:

On behalf of BlackRock ETF Trust (the “Trust”), transmitted herewith for filing with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), and the Investment Company Act of 1940, as amended (the “Investment Company Act”), is Post-Effective Amendment No. 17 to the Trust’s Registration Statement on Form N-1A (the “Registration Statement”). The Registration Statement contains a Prospectus for shares of two new series of the Trust, BlackRock U.S. Carbon Transition Readiness ETF and BlackRock World ex U.S. Carbon Transition Readiness ETF (the “Funds”), as well as a Statement of Additional Information relating to the Funds.

In Investment Company Act Release No. 13768 (February 15, 1984) (the “Release”), the Division of Investment Management announced review procedures for investment companies providing for expedited cursory or partial review of investment company registration statements, in the discretion of the staff, if certain conditions are met. The Release requests that information be furnished to the staff with respect to the extent that the filing contains disclosure information which is similar to information previously reviewed by the staff in other filings of the same complex.

In that regard, reference is made to Post-Effective Amendment No. 6 to the Registration Statement on Form N-1A of the Trust on behalf of BlackRock Future Innovators ETF, which was filed on June 3, 2020 (the “Prior Filing”). While the Funds’ Prospectus and Statement of

 

Sidley Austin (NY) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.


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Additional Information are filed on a stand-alone basis, the disclosure therein is substantively similar to the Prior Filing with respect to the following matters:

Prospectus:

 

   

Management

 

     

Administrator, Custodian and Transfer Agent

 

     

Conflicts of Interest

 

   

Distribution

 

   

Financial Highlights

 

   

Disclaimers

Statement of Additional Information:

 

   

Proxy Voting Policy

 

   

Investment Policies

 

     

Fundamental Investment Policies

 

   

Continuous Offering

 

   

Management

 

     

Potential Conflicts of Interest

 

   

Investment Advisory, Administrative and Distribution Services

 

     

Code of Ethics

 

     

Anti-Money Laundering Requirements

 

     

Administrator, Custodian and Transfer Agent

 

     

Distributor

 

     

Securities Lending

 

   

Determination of Net Asset Value

 

   

Brokerage Transactions

 

   

Additional Information Concerning the Trust

 

   

Creation and Redemption of Creation Units

 

     

Cash Purchase Method

 

     

Procedures for Creation of Creation Units

 

     

Purchase Orders

 

     

Timing of Submission of Purchase Orders

 

     

Acceptance of Orders for Creation Units

 

     

Cash Redemption Method

 

   

Financial Statements

 

   

Miscellaneous Information

 

   

Appendix A2 – BlackRock’s Global Corporate Governance & Engagement Principals

 

   

Appendix A3 – BlackRock’s Corporate Governance and Proxy Voting Guidelines for U.S. Securities

 

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We would be pleased to provide you with any additional information you may require or with copies of the materials referred to above. We would appreciate any comments the Commission staff may have as soon as possible.

Please direct any communications relating to this filing to Jesse C. Kean at (212) 839-8615.

 

Very truly yours,
/s/ Douglas E. McCormack
Douglas E. McCormack

Enclosures

 

cc:

John A. MacKinnon

    

Jesse Kean

    

Janey Ahn

    

Dean Caruvana

 

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