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VINCE NGUYEN
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vince.nguyen@dechert.com | ||||
+1 212 698 3566 Direct | ||||
+1 212 698 0617 Fax |
November 2, 2021
VIA EDGAR
Christopher Bellacicco
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549-4644
Re: | Goldman Sachs ETF Trust (the Registrant) |
SEC File Nos. 333-200933 and 811-23013
Post-Effective Amendment No. 343 to the Registration Statement on Form N-1A
Dear Mr. Bellacicco:
This letter responds to the comments you provided to Claire Hinshaw and me of Dechert LLP during a telephonic discussion on November 1, 2021, with respect to your review of Post-Effective Amendment No. 343 to the Registrants registration statement filed with the U.S. Securities and Exchange Commission (SEC) on June 4, 2021, with such revisions as discussed in the Registrants response letter dated October 28, 2021. The Amendment was filed pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the 1933 Act) for the purpose of registering shares of Goldman Sachs Future Real Estate and Infrastructure Equity ETF, a new series of the Registrant (the Fund). We have reproduced your additional comments below, followed by the Registrants responses. Capitalized terms have the meanings attributed to such terms in the registration statement.
Prospectus
Comment 1. The Staff notes that the SummaryPrincipal Investment Strategies section states that [t]he Investment Adviser employs a fundamental investment process that may integrate environmental, social and governance (ESG) factors. Please disclose the ESG factors or criteria the Investment Adviser may consider in the principal strategies disclosure responsive to Item 4 of Form N-1A.
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Mr. Christopher Bellacicco November 2, 2021 Page 2 |
Response 1. The Registrant respectfully declines to make any revision in response to this comment at this time. As noted in the prior response letter, examples of the ESG criteria that the Fund will consider are currently disclosed in the Investment Management ApproachPrincipal Investment Strategies section of the Prospectus. Consistent with Item 4 of Form N-1A, the SummaryPrincipal Investment Strategies section of the Prospectus summarizes how the Fund intends to achieve its investment objective by identifying the Funds principal investment strategies. This section includes a summary of the Investment Advisers fundamental investment process, which may integrate environmental, social and governance factors (ESG) with traditional fundamental factors. The Registrant believes that the Funds layered disclosure approach is consistent with Form N-1A and prior published SEC Staff guidance1 and is appropriate in light of the Funds principal investment strategies.
Comment 2. With respect to the use of the word house within the disclosure regarding the Key Themes in the SummaryPrincipal Investment Strategies and Investment Management ApproachPrincipal Investment Strategies section, please consider revising for clarity.
Response 2. The disclosure referenced above has been revised to replace the word house with facilitate in response to this comment.
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We believe that the foregoing has been responsive to the Staffs comments. Please call the undersigned at (212) 698-3566 if you wish to discuss this correspondence further.
Sincerely,
/s/ Vince Nguyen
Vince Nguyen
cc: | Caroline Kraus, Goldman Sachs Asset Management, L.P. |
Melissa ONeill, Goldman Sachs Asset Management, L.P.
Stephanie Capistron, Dechert LLP
1 | See Guidance Regarding Mutual Fund Enhanced Disclosure, SEC Staff IM Guidance Update (No. 2014-08) (June 2014), available at https://www.sec.gov/investment/im-guidance-2014-08.pdf. |