Invesco Exchange-Traded Self-Indexed Fund Trust

2.

We have revised the disclosure in the “Principal Investment Strategies” section pursuant to the staff’s request. The disclosure under that heading now reads as follows:

The Fund generally will invest at least 80% of its total assets in the securities that comprise the Underlying Index.

Strictly in accordance with its guidelines and mandated procedures, FTSE International Limited (“FTSE” or the “Index Provider”) compiles and maintains the Underlying Index, which is an index of foreign equity securities designed to reflect a dynamic combination of “factor investing” strategies that, in the view of the Index Provider, have historically outperformed other factors during various parts of the economic cycle. The Underlying Index’s universe of investable stocks are taken from the FTSE Developed ex US Index (the “Parent Index”), which comprises large-capitalization (85%) and mid-capitalization (15%) stocks of companies located in 24 developed market countries around the world, excluding the United States. The Parent Index is derived from the FTSE Global Equity Index Series (GEIS), which covers 98% of the world’s investable market capitalization.

A factor is a stock characteristic that is associated with a security’s risk and return profile (e.g., high quality, high momentum or low volatility). The Underlying Index’s rules-based framework seeks to identify equity securities that tend to exhibit various investment factors to a greater extent than the overall market, depending on the overall economic environment. The Underlying Index emphasizes investments that exhibit the following factors: low volatility, momentum, quality, size and value. At any given time, depending on the current stage of the economic cycle of the overall market, the Underlying Index will target different subsets (that is, two or three) of those five factors (referred to as “factor configurations”). The Underlying Index is designed to utilize factor configurations that, in the view of the Index Provider, have historically outperformed other factors in certain stages of the economic cycle. The specific factor configurations used by the Underlying Index will change depending on which of the following four stages of the economic cycle currently is prevalent: recovery, expansion, slowdown and contraction. These four stages are defined as follows:

•  Recovery: when growth is below trend but accelerating.

•  Expansion: when growth is above trend and accelerating.

•  Slowdown: when growth is above trend but decelerating.

•  Contraction: when growth is below trend and decelerating.

Invesco Indexing LLC (“Invesco Indexing”) identifies which stage of the economic cycle it currently believes the market to be in evaluating leading economic indicators and information regarding global risk appetite (such as manufacturing business surveys, labor market conditions, monetary conditions and consumer sentiment surveys). Each month, Invesco Indexing informs the Index Provider on the current stage of the economic cycle, and the Index Provider uses that information to determine the appropriate factor configuration for the Underlying Index during that month. Each of the four stages is correlated to a specific, predetermined factor configuration. For example, the Underlying Index will emphasize exposure to equity securities that exhibit size and value factors during the recovery stage; size, value and momentum factors during the expansion stage; volatility and quality factors during the slowdown stage; and momentum, quality and volatility factors during the contraction stage.

To determine which securities within the Parent Index are eligible for inclusion in the Underlying Index in a given factor configuration, each constituent in the Parent Index is assigned a multi-factor score based on the extent to which the security exhibits a factor relative to the other constituents in the Parent Index. The multi-factor score is the product of the security’s individual factor scores, each of which is calculated based on certain aspects of the issuer, as set forth below.

•  Value. A company’s value factor score is based on an equally-weighted composite of cash flow yield, earnings yield, and sales to price ratio, calculated based on the company’s total market capitalization and information reported in the company’s most recent annual financial statement as of the last business day of the prior month.

•  Momentum. A company’s momentum factor score is based on historical total return over the 11 months ending on the last business day of the prior month.

•  Quality. A company’s quality factor score is based on a composite of three measures of profitability (return on assets, change in asset turnover and accruals) and a single measure of leverage, calculated based on information reported in the company’s most recent annual financial statement.

•  Low Volatility. A company’s volatility factor score is based on the standard deviation of weekly total returns to a company’s stock price over the trailing five years ending on the last business day of the prior month.

•  Size. A company’s size factor score is based on total market capitalization as of the last business day of the prior month.

An initial weight for each security is determined from the product of the security’s multi-factor score and its weight in the Parent Index. The Underlying Index’s methodology will exclude securities from the Underlying Index if their relevant factor characteristics fall below certain relative thresholds, as set forth in the methodology rules of the Underlying Index, or if their adjusted weights fall below a certain de minimis amount (0.02%). Finally, a maximum security weight limit is applied to ensure no security weight exceeds a fixed level (5%).

The Underlying Index is sponsored by the Index Provider, which is unaffiliated with the Fund, Invesco Indexing or Invesco Capital Management LLC, the Fund’s investment adviser (the “Adviser”). However, since Invesco Indexing provides the Index Provider with monthly data relating to the stage of the economic cycle, Invesco Indexing may also be deemed a creator and sponsor of the Underlying Index. Invesco Indexing is affiliated with the Adviser and Invesco Distributors, Inc., the Fund’s distributor (the “Distributor”).

The Fund employs a “full replication” methodology in seeking to track the Underlying Index, meaning that the Fund generally invests in all of the securities comprising the Underlying Index in proportion to their weightings in the Underlying Index.

The Fund is “non-diversified” and therefore is not required to meet certain diversification requirements under the Investment Company Act of 1940, as amended (the “1940 Act”).

The “Principal Investment Strategies” section states that securities in the Parent Index are excluded from the Underlying Index “if their relevant factor characteristics fall below an algorithmically-determined threshold, or if their adjusted weights fall below a certain de minimis amount.” With respect to this disclosure:

•  Please revise the language, using plain English, to explain how the Underlying Index methodology determines if a security is included or excluded.

•  Please describe the “algorithmically-determined” threshold.

We note the following disclosure in the Prospectus: “Since Invesco Indexing provides data to the Index Provider, Invesco Indexing may be deemed a creator and sponsor of the Underlying Index.” In light of that disclosure:

•  Please explain how the Underlying Index is constructed (i.e., is it a collaboration with FTSE, or is it developed by Invesco Indexing and serviced by FTSE?

•  Please address supplementally whether the Fund’s adviser or Invesco Indexing plays any role with respect to the Underlying Index other than Invesco Indexing’s role providing the data signal to the Index Provider.

We confirm that Peter Hubbard is jointly and primarily responsible, with the other listed portfolio managers, for the day-to-day management of the Fund. In addition, we have revised the disclosure under the statutory prospectus section titled “Management of the Fund—Portfolio Managers” to clarify this point:

In this capacity, Mr. Hubbard oversees a team of portfolio managers (collectively with Mr. Hubbard, the “Portfolio Managers”) who are jointly and primarily responsible for the day-to-day management of the Fund.

Adam Henkel, Esq.

Management Fees

Other Expenses⁽¹⁾

Total Annual Fund Operating Expenses

“Other Expenses” are based on estimated amounts for the current fiscal year.

1 Year

$35