UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number 811-23477
BNY Mellon ETF Trust
(Exact name of registrant as specified in charter)
240 Greenwich Street
_____________New York, New York 10286_____________
(Address of principal executive offices) (Zip code)
Deirdre Cunnane, Esq.
240 Greenwich Street
_________________New York, New York 10286_____________
(Name and address of agent for service)
Registrant's telephone number, including area code: (212) 922-6400
Date of fiscal year end: June 30
Date of reporting period: December 31, 2021
The following N-CSR relates only to the Registrant's series listed below and does not relate to any series of the Registrant with a different fiscal year end and, therefore, different N-CSR reporting requirements. A separate N-CSR will be filed for any series with a different fiscal year end, as appropriate
BNY Mellon Ultra Short Income ETF
Form N-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may use the information provided on Form N-CSR in its regulatory, disclosure review, inspection, and policymaking roles.
A registrant is required to disclose the information specified by Form N-CSR, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained in Form N-CSR unless the Form displays a currently valid Office of Management and Budget ("OMB") control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission,
100 F Street, NE, Washington, DC 20549
. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.Item 1. Reports to Stockholders.
(a)
The following is a copy of the report transmitted to shareholders pursuant to Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1).
BNY
Mellon
ETF
Trust
Semiannual
Report
December
31,
2021
BNY
Mellon
Ultra
Short
Income
ETF
Contents
The
Fund
Discussion
of
Fund
Performance
3
Understanding
Your
Fund’s
Expenses
5
Statement
of
Investments
6
Statement
of
Assets
and
Liabilities
8
Statement
of
Operations
9
Statement
of
Changes
in
Net
Assets
10
Financial
Highlights
11
Notes
to
Financial
Statements
12
Information
About
the
Approval
of
the
Fund’s
Management
and
Sub-Investment
Advisory
Agreements
16
FOR
MORE
INFORMATION
Back
Cover
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time.
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paper.
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few
minutes.
The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
•
Not
Bank-Guaranteed
•
May
Lose
Value
3
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
For
the
period
August
9,
2021,
through
December
31,
2021,
as
provided
by
Stephen
Murphy,
CFA,
and
Anthony
Honko,
of
Dreyfus
Cash
Investment
Strategies,
a
division
of
Mellon
Investment
Corporation,
the
Sub-Adviser
Market
and
Fund
Performance
Overview
For
the
period
from
August
9,
2021,
the
fund’s
inception,
through
December
31,
2021,
the
BNY
Mellon
Ultra
Short
Income
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
-0.23%.
1
In
comparison,
the
ICE
BofA
Merrill
Lynch
3-Month
U.S.
Treasury
Bill
Index
(the
“Index”),
the
fund’s
benchmark,
returned
0.02%
for
the
same
period.
2
Despite
increasing
inflationary
pressures,
short-term,
fixed-
income
yields
remained
near
historically
low
levels
due
to
accommodative
monetary
policy
from
the
U.S.
Federal
Reserve
(the
“Fed”)
in
response
to
the
COVID-19
pandemic.
The
fund
underperformed
the
Index
largely
as
a
result
of
its
exposure
to
fixed
corporate
and
securitized
credit
at
a
time
of
rising
yields.
The
Fund’s
Investment
Approach
The
fund
seeks
high
current
income
consistent
with
the
maintenance
of
liquidity
and
low
volatility
of
principal.
To
pursue
its
goal,
the
fund
normally
invests
in
investment-grade,
U.S.
dollar-denominated
fixed,
variable,
and
floating-rate
debt
or
cash
equivalents.
The
fund
typically
seeks
to
maintain
an
effective
duration
of
one
year
or
less,
although,
under
certain
market
conditions,
such
as
in
periods
of
significant
volatility
in
interest
rates
and
spreads,
the
fund's
duration
may
be
longer
than
one
year.
The
fund's
portfolio,
under
normal
market
conditions,
will
have
an
average
credit
rating
of
at
least
A
or
equivalent.
The
fund's
portfolio
managers
seek
to
achieve
what
they
believe
provides
the
optimal
portfolio
for
the
fund
in
terms
of
preservation
of
principal,
liquidity
and
producing
high
current
income.
To
do
so,
the
portfolio
managers
use
a
top-down
and
bottom-up
investment
process
and
leverage
the
breadth
and
depth
of
Dreyfus
Cash
Investment
Strategies'
research
resources.
The
portfolio
managers
focus
on
preservation
of
principal
and
downside
protection
by
proactively
monitoring
issuer
and
counterparty
risk
and
ensure
appropriate
portfolio
liquidity
through
a
combination
of
overnight
investments
and
short-term,
highly
liquid
securities.
Rising
Yields
Limit
Fixed-Income
Performance
During
the
months
prior
to
the
fund’s
launch,
fixed-income
markets
experienced
increasing
inflationary
pressures
arising
from
pandemic-related,
supply-chain
bottlenecks
and
a
tight
labor
market.
Inflation
was
also
driven
by
money
remaining
in
the
economy
from
the
massive
government
stimulus
packages
passed
in
response
to
pandemic.
These
inflationary
pressures
drove
bond
yields
higher,
causing
bond
prices
to
decline
(bond
yields
and
prices
typically
move
in
opposite
directions).
While
the
Fed
opined,
throughout
most
of
2021,
that
inflation
was
likely
to
prove
transitory,
these
overriding
market
dynamics
remained
in
place
throughout
the
reporting
period.
In
September
2021,
the
Fed’s
tone
shifted,
as
members
indicated
a
willingness
to
consider
reducing
accommodative
policies
sooner
rather
than
later
due
to
the
unexpected
level
and
persistence
of
inflationary
forces
affecting
the
economy.
As
inflationary
pressures
continued
to
mount,
Fed
rhetoric
grew
increasingly
hawkish.
In
November,
the
Fed
used
the
word
“transitory”
when
describing
inflation.
At
the
same
time,
the
Fed
forecast
a
possible
end
to
their
asset
purchase
program
as
early
as
June
2022,
thereby
increasing
the
likelihood
of
one
or
more
rate
hikes
later
that
year.
In
December,
the
Fed
revised
their
estimate
of
an
end
to
quantitative
easing
in
March
2022,
leading
the
market
to
widely
anticipate
multiple
hikes
in
2022.
Such
a
move
would
represent
a
significant
rise
in
interest
rates,
particularly
affecting
the
short
end
of
yield
curve.
Nevertheless,
while
the
Fed
resisted
more
aggressive
and
immediate
action,
credit
spreads
continued
to
trade
near
historical
lows,
with
only
modest
widening
in
the
1-to-3-year
space
on
expectations
of
less
accommodative
policy.
Duration
and
Fixed-Credit
Exposure
Detract
from
Fund
Performance
The
fund’s
exposure
to
the
1-to-3-year
part
of
yield
curve
through
investments
in
fixed-credit
securities
detracted
from
performance
relative
to
the
Index.
The
fund’s
weakest
performers
were
corporate
fixed
instruments,
which
were
undermined
by
slight
credit-spread
widening
due
to
the
upward
movement
of
yields
in
the
2-to-3-year
space.
Holdings
of
securitized
instruments
also
detracted
from
relative
returns,
albeit
to
a
lesser
degree
due
to
their
slightly
shorter
average
duration.
Conversely,
the
fund’s
relative
performance
benefited
from
substantial
exposure
to
money
market
securities,
particularly
commercial
paper,
due
to
very
short
duration
of
those
securities.
Performance
also
benefited
from
a
moderate
allocation
to
floating-rate,
corporate
bonds,
and
from
the
shortening
of
the
fund’s
average
duration
toward
the
end
of
the
period.
Seeing
Challenges
and
Opportunities
in
a
Tightening
Environment
As
of
the
end
of
the
period,
we
see
few
signs
of
easing
in
the
inflationary
trends
that
challenge
the
fixed-income
market.
Accordingly,
we
expect
the
Fed
to
tighten
monetary
policy
in
2022
as
it
attempts
to
balance
its
mandate
of
restraining
inflation
against
the
risk
of
hobbling
the
economy
through
overly
aggressive
rate
increases.
While
such
an
environment
is
likely
to
slightly
hinder
fund
performance
in
the
short
term,
we
believe
that
a
less
accommodative
monetary
policy,
rising
rates
and
widening
credit
spreads
are
also
likely
to
create
attractive
investment
opportunities
in
the
corporate
bond
market.
Currently,
the
fund
holds
its
largest
position
in
commercial
paper,
a
moderate
position
in
corporate
fixed
securities,
a
smaller
but
growing
position
in
floating-rate
corporates,
and
its
smallest
position
in
securitized
holdings.
We
continue
to
look
for
opportunities
to
swap
fixed-rate
exposure
for
floating-rate
instruments,
and
to
further
reduce
duration
where
advantageous.
4
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
We
remain
committed
to
managing
the
fund
to
provide
liquidity
as
needed,
while
working
to
reduce
interest-rate
exposure
in
the
face
of
the
prevailing
tightening
cycle.
January
18,
2022
1
ETFs
trade
like
stocks,
are
subject
to
investment
risk,
including
possible
loss
of
principal.
ETF
shares
are
listed
on
an
exchange,
and
shares
are
generally
purchased
and
sold
in
the
secondary
market
at
market
price.
At
times,
the
market
price
may
be
at
a
premium
or
discount
to
the
ETF’s
per
share
NAV.
In
addition,
ETFs
are
subject
to
the
risk
that
an
active
trading
market
for
an
ETF’s
shares
may
not
develop
or
be
maintained.
Buying
or
selling
ETF
shares
on
an
exchange
may
require
payment
of
brokerage
commissions.
2
Source:
FactSet
-
The
ICE
BofA
Merrill
Lynch
3-Month
Treasury
Bill
Index
is
an
unmanaged
market
index
of
US
Treasury
securities
maturing
in
90
days
that
assumes
reinvestment
of
all
income.
Investors
cannot
invest
directly
in
any
index.
Bonds
are
subject
generally
to
interest-rate,
credit,
liquidity
and
market
risks,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
Generally,
all
other
factors
being
equal,
bond
prices
are
inversely
related
to
interest-rate
changes,
and
rate
increases
can
cause
price
decline.
Recent
market
risks
include
pandemic
risks
related
to
COVID-19.
The
effects
of
COVID-19
have
contributed
to
increased
volatility
in
global
markets
and
will
likely
affect
certain
countries,
companies,
industries
and
market
sectors
more
dramatically
than
others.
To
the
extent
the
fund
may
overweight
its
investments
in
certain
countries,
companies,
industries
or
market
sectors,
such
positions
will
increase
the
fund's
exposure
to
risk
of
loss
from
adverse
developments
affecting
those
countries,
companies,
industries
or
sectors.
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
5
As
a
shareholder
of
the
fund,
you
pay
ongoing
expenses,
such
as
management
fees
and
other
expenses.
Using
the
information
below,
you
can
estimate
how
these
expenses
affect
your
investment
and
compare
them
with
the
expenses
of
other
funds.
For
more
information,
see
your
fund’s
prospectus
or
talk
to
your
financial
adviser.
Actual
Expenses
The
information
under
each
column
in
the
table
below
entitled
“Actual”
provides
information
about
on
how
much
a
$1,000
investment
would
be
worth
at
the
close
of
the
period,
assuming
net
asset
value
total
returns
and
actual
expenses.
You
may
use
the
information
in
these
columns,
together
with
the
amount
you
invested,
to
estimate
the
expenses
that
you
paid
over
the
period.
Simply
divide
your
account
value
by
$1,000
(for
example,
an
$8,600
account
value
divided
by
$1,000
=
8.6),
then
multiply
the
result
by
the
number
for
the
fund
under
the
heading
entitled
“Expenses
paid
for
the
period”
to
estimate
the
expenses
you
paid
on
your
account
during
this
period.
Hypothetical
Example
For
Comparison
Purposes
The
Securities
and
Exchange
Commission
(“SEC”)
has
established
guidelines
to
help
investors
assess
fund
expenses.
The
information
under
each
column
in
the
table
entitled
“Hypothetical”
provides
information
about
hypothetical
account
values
and
hypothetical
expenses
based
on
the
fund’s
actual
expense
ratio
and
an
assumed
rate
of
return
of
5%
per
year
before
expenses,
which
is
not
the
fund’s
actual
return.
The
hypothetical
account
values
and
expenses
may
not
be
used
to
estimate
the
actual
ending
account
balance
or
expenses
you
paid
for
the
period.
You
may
use
this
information
to
compare
the
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
To
do
so,
compare
this
5%
hypothetical
example
with
the
5%
hypothetical
examples
that
appear
in
the
shareholder
reports
of
the
other
funds.
Please
note
that
the
expenses
shown
in
the
table
are
meant
to
highlight
your
ongoing
costs
only
and
do
not
reflect
any
transactional
costs,
such
as
brokerage
commissions
paid
on
purchases
and
sales
of
fund
shares.
Therefore,
the
ending
account
values
and
expenses
paid
for
the
period
in
the
table
are
useful
in
comparing
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
In
addition,
if
these
transactional
costs
were
included,
your
costs
would
have
been
higher.
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
period
August
11,
2021
(commencement
of
operations)
to
December
31,
2021.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
143/365.
Hypothetical
expenses
reflect
projected
activity
for
the
full
six
month
period
for
purposes
of
comparability
and
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
184/365.
The
actual
ending
account
value
is
based
on
the
actual
total
return
of
the
fund
for
the
period,
after
actual
expenses
and
will
differ
from
the
hypothetical
ending
account
value
which
is
based
on
the
fund’s
expense
ratio
and
a
hypothetical
annual
return
of
5%
before
expenses.
For
the
six
months
ended
December
31,
2021
Beginning
account
value
($)
Ending
account
value($)
Expense
paid
for
the
period
($)
Annualized
expense
ratios
for
the
period
(%)
Actual
Hypothetical
Actual
Hypothetical
Actual
(a)
Hypothetical
(a)
BNY
Mellon
Ultra
Short
Income
ETF
1,000.00
1,000.00
997.70
1,024.60
0.47
0.61
0.12
6
STATEMENT
OF
INVESTMENTS
December
31,
2021
(Unaudited)
BNY
Mellon
Ultra
Short
Income
ETF
Description
Principal
Amount
($)
Value
($)
Asset-Backed
Securities
–
9.4%
Drive
Auto
Receivables
Trust,
Series
2021-2,
Class
A3,
0.35%,
3/17/2025
300,000
299,211
Ford
Credit
Auto
Lease
Trust,
Series
2021-B,
Class
A4,
0.40%,
12/15/2024
350,000
346,354
Ford
Credit
Floorplan
Master
Owner
Trust,
Series
2019-2,
Class
A,
3.06%,
4/15/2026
300,000
312,814
GMF
Floorplan
Owner
Revolving
Trust,
Series
2020-1,
Class
A,
0.68%,
8/15/2025
(a)
300,000
298,742
Honda
Auto
Receivables
Owner
Trust,
Series
2021-3,
Class
A3,
0.41%,
11/18/2025
350,000
346,417
Hyundai
Auto
Lease
Securitization
Trust,
Series
2021-C,
Class
A4,
0.48%,
9/15/2025
(a)
350,000
346,138
Kubota
Credit
Owner
Trust,
Series
2020-1A,
Class
A4,
2.26%,
7/15/2026
(a)
300,000
306,114
Oscar
US
Funding
XII
LLC,
Series
2021-1A,
Class
A3,
0.70%,
4/10/2025
(a)
300,000
298,548
Total
Asset-Backed
Securities
(cost
$2,581,934)
2,554,338
Commercial
Paper
–
50.9%
ABS
Finance
Ltd.,
0.20%,
8/01/2022
(b)
750,000
749,991
Australia
&
New
Zealand
Banking
Group
Ltd.,
0.33%,
11/08/2022
(b)
750,000
747,478
Bank
of
Nova
Scotia
(The),
0.19%,
7/28/2022
(b)
500,000
499,030
BPCE
SA,
0.35%,
11/08/2022
(b)
750,000
747,016
Canadian
Imperial
Bank
of
Commerce,
0.19%,
8/12/2022
(b)
750,000
748,306
Collateralized
Commercial
Paper
V
Co.,
LLC,
0.15%,
2/28/2022
(b)
750,000
749,764
Cooperatieve
Rabobank
U.A.,
0.16%,
5/06/2022
(b)
750,000
749,535
DBS
Bank
Ltd.,
0.13%,
2/01/2022
(b)
700,000
699,938
Landesbank
Baden-Wurttemberg,
0.16%,
2/04/2022
(b)
750,000
749,921
LMA
S.A.
/
LMA
Americas
LLC,
0.14%,
2/09/2022
(b)
750,000
749,879
Mitsubishi
UFJ
Trust
and
Banking
Corp.,
0.15%,
2/10/2022
(b)
750,000
749,909
National
Bank
of
Canada,
0.14%,
2/18/2022
(b)
750,000
749,874
Sheffield
Receivables
Co.
LLC,
0.15%,
2/08/2022
(b)
300,000
299,954
Skandinaviska
Enskilda
Banken
AB,
0.17%,
5/02/2022
(b)
750,000
749,426
Societe
Generale
North
America,
Inc.,
0.36%,
11/07/2022
(b)
750,000
746,573
Starbird
Funding
Corp.,
0.27%,
4/20/2022
(b)
250,000
249,803
Svenska
Handelsbanken
AB,
0.15%,
6/09/2022
(b)
850,000
849,150
Swedbank
AB,
0.15%,
4/04/2022
(b)
800,000
799,670
United
Overseas
Bank
Ltd.,
0.25%,
6/10/2022
(b)
800,000
798,937
Westpac
Securities
NZ
Ltd.,
0.17%,
5/05/2022
(b)
750,000
749,563
Total
Commercial
Paper
(cost
$13,936,898)
13,933,717
Corporate
Bonds
–
37.8%
Auto
Manufacturers
–
3.3%
American
Honda
Finance
Corp.,
2.90%,
2/16/2024
300,000
311,397
BMW
US
Capital
LLC,
0.43%
(3
Month
SOFR
+
0.38%),
8/12/2024
(a)(c)
300,000
300,908
Toyota
Motor
Credit
Corp.,
0.50%,
6/18/2024
300,000
295,728
908,033
Banks
–
18.1%
ASB
Bank
Ltd.,
3.13%,
5/23/2024
(a)
350,000
366,430
BNY
Mellon
Ultra
Short
Income
ETF
(continued)
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
–
37.8%
(continued)
Banks
–
18.1%
(continued)
Bank
of
America
Corp.,
0.59%
(3
Month
BSBY
+
0.43%),
5/28/2024
(c)
300,000
300,152
Bank
of
Montreal,
0.40%
(3
Month
SOFR
+
0.35%),
12/08/2023
(c)
350,000
350,190
Canadian
Imperial
Bank
of
Commerce,
0.45%
(3
Month
SOFR
+
0.40%),
12/14/2023
(c)
300,000
299,917
Credit
Agricole
SA,
3.75%,
4/24/2023
(a)
300,000
310,913
Credit
Suisse
Group
AG,
3.57%,
1/09/2023
(a)
750,000
750,214
Goldman
Sachs
Group,
Inc.
(The),
3.63%,
1/22/2023
750,000
772,589
Nordea
Bank
Abp
,
0.63%,
5/24/2024
(a)
300,000
296,484
PNC
Financial
Services
Group,
Inc.
(The),
3.50%,
1/23/2024
300,000
314,268
Royal
Bank
of
Canada,
2.55%,
7/16/2024
300,000
310,126
Sumitomo
Mitsui
Financial
Group,
Inc.,
0.51%,
1/12/2024
300,000
296,709
UBS
AG,
0.45%,
2/09/2024
(a)
300,000
295,619
Westpac
Banking
Corp.,
0.35%
(3
Month
SOFR
+
0.30%),
11/18/2024
(c)
300,000
299,814
4,963,425
Beverages
–
1.1%
PepsiCo,
Inc.,
0.40%,
10/07/2023
300,000
298,489
298,489
Diversified
Financial
Services
–
2.4%
American
Express
Co.,
3.40%,
2/22/2024
300,000
314,766
Charles
Schwab
Corp.
(The),
0.55%
(3
Month
SOFR
+
0.50%),
3/18/2024
(c)
350,000
351,309
666,075
Insurance
–
1.2%
American
International
Group,
Inc.,
4.13%,
2/15/2024
300,000
318,711
318,711
Machinery-Construction
&
Mining
–
1.1%
Caterpillar
Financial
Services
Corp.,
0.45%,
9/14/2023
300,000
298,755
298,755
Machinery-Diversified
–
1.1%
John
Deere
Capital
Corp.,
0.45%,
1/17/2024
300,000
297,212
297,212
Pharmaceuticals
–
3.4%
AbbVie,
Inc.,
2.60%,
11/21/2024
300,000
311,472
AstraZeneca
Finance
LLC,
0.70%,
5/28/2024
300,000
297,751
GlaxoSmithKline
Capital
PLC,
3.00%,
6/01/2024
300,000
314,013
923,236
Pipelines
–
1.3%
Enbridge,
Inc.,
0.45%
(3
Month
SOFR
+
0.40%),
2/17/2023
(c)
350,000
350,107
350,107
Retail
–
1.1%
Walmart,
Inc.,
2.85%,
7/08/2024
300,000
313,658
313,658
Software
–
1.1%
Salesforce.com,
Inc.,
0.63%,
7/15/2024
300,000
297,376
297,376
Telecommunications
–
2.6%
AT&T,
Inc.,
0.69%
(3
Month
SOFR
+
0.64%),
3/25/2024
(c)
350,000
350,120
7
(a)
Security
exempt
from
registration
pursuant
to
Rule
144A
under
the
Securities
Act
of
1933.
These
securities
may
be
resold
in
transactions
exempt
from
registration,
normally
to
qualified
institutional
buyers.
At
December
31,
2021,
these
securities
were
valued
at
$3,570,110
or
13.04%
of
net
assets.
(b)
Security
is
a
discount
security.
Income
is
recognized
through
the
accretion
of
discount.
(c)
Variable
rate
security
-
rate
shown
is
the
interest
rate
in
effect
at
period
end.
Security
description
also
includes
the
reference
rate
and
spread
if
published
and
available.
(d)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
December
31,
2021
are
as
follows:
(e)
The
rate
shown
is
the
1-day
yield
as
of
December
31,
2021.
See
Notes
to
Financial
Statements
BNY
Mellon
Ultra
Short
Income
ETF
(continued)
Description
Principal
Amount
($)
Value
($)
Corporate
Bonds
–
37.8%
(continued)
Telecommunications
–
2.6%
(continued)
Verizon
Communications,
Inc.,
0.55%
(3
Month
SOFR
+
0.50%),
3/22/2024
(c)
350,000
351,469
701,589
Total
Corporate
Bonds
(cost
$10,431,225)
10,336,666
Negotiable
Bank
Certificates
of
Deposit
–
1.8%
Nordea
Bank
Abp
,
0.19%,
9/19/2022
500,000
499,560
Total
Negotiable
Bank
Certificates
of
Deposit
(cost
$500,000)
499,560
Shares
Investment
Companies
–
0.0%
Registered
Investment
Companies
–
0.0%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
0.01%
(d)(e)
(cost
$11,989)
11,989
11,989
Total
Investments
(cost
$27,462,046)
99.9%
27,336,270
Cash
and
Receivables
(Net)
0.1%
39,833
Net
Assets
100.0%
27,376,103
BSBY—Bloomberg
Short-Term
Bank
Yield
Index
SOFR—Secured
Overnight
Financing
Rate
Description
Value
8/09/21
Purchases
($)
1
Sales
($)
Net
Realized
Gain
(Loss)
($)
Net
Change
in
Unrealized
Appreciation
(Depreciation)
($)
Value
12/31/21
Net
Assets
(%)
Dividends/
Distributions
($)
Investment
Companies
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
17,531,643
(17,519,654)
—
—
11,989
0.0
12
Total
—
17,531,643
(17,519,654)
—
—
11,989
0.0
12
1
Includes
reinvested
dividends/distributions.
Portfolio
Summary
(Unaudited)
†
Value
(%)
Financial
83.8
Consumer,
Non-cyclical
4.5
Consumer,
Cyclical
4.4
Communications
2.6
Industrial
2.2
Energy
1.3
Technology
1.1
Registered
Investment
Companies
0.0
99.9
†
Based
on
net
assets.
8
STATEMENT
OF
ASSETS
AND
LIABILITIES
(Unaudited)
December
31,
2021
space
See
Notes
to
Financial
Statements
Assets
($):
Investments
in
securities—See
Statement
of
Investments
†
:
–
Unaffiliated
issuers
27,324,281
Affiliated
issuers
11,989
Interest
receivable
59,979
Dividends
receivable
2
27,396,251
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—Note
3(b)
2,922
Distributions
payable—Note
2(e)
17,226
20,148
Net
Assets
($)
27,376,103
Composition
of
Net
Assets
($):
Paid-in
capital
27,510,666
Total
distributable
earnings
(loss)
(134,563)
Net
Assets
($)
27,376,103
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
550,001
Net
asset
value
per
share
49.77
Market
price
per
share
49.77
†
Investments
at
cost
($)
Unaffiliated
issuers
27,450,057
Affiliated
issuers
11,989
9
STATEMENT
OF
OPERATIONS
(Unaudited)
For
the
Period
from
August
11,
2021
(commencement
of
operations)
to
December
31,
2021
space
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Affiliated
issuers
12
Interest
73,721
Total
Income
73,733
Expenses:
Management
fees—Note
3(a)
13,153
Total
Expenses
13,153
Investment
Income—Net
60,580
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
(8,841)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
(125,776)
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
(134,617)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
(74,037)
10
STATEMENT
OF
CHANGES
IN
NET
ASSETS
space
See
Notes
to
Financial
Statements
For
the
Period
from
August
11,
2021
(a)
to
December
31,
2021
(Unaudited)
Operations
($):
Investment
income—net
60,580
Net
realized
gain
(loss)
on
investments
(8,841)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
(125,776)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
(74,037)
Distributions
($):
Distributions
to
shareholders
(60,526)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
29,999,537
Cost
of
shares
redeemed
(2,488,871)
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
27,510,666
Total
Increase
(Decrease)
in
Net
Assets
27,376,103
Net
Assets
($):
Beginning
of
Period
—
End
of
Period
27,376,103
Changes
in
Shares
Outstanding:
Shares
sold
600,001
Shares
redeemed
(50,000)
Net
Increase
(Decrease)
in
Shares
Outstanding
550,001
(a)
Commencement
of
operations.
11
FINANCIAL
HIGHLIGHTS
The
following
tables
describe
the
performance
for
the
fiscal
period
indicated
and
these
figures
have
been
derived
from
the
fund’s
financial
statements.
See
Notes
to
Financial
Statements
For
the
Period
from
August
11,
2021
(a)
to
December
31,
2021
(Unaudited)
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
50.00
Investment
Operations:
Investment
income—net
(b)
0.11
Net
realized
and
unrealized
gain
(loss)
on
investments
(0.23)
Total
from
Investment
Operations
(0.12)
Distributions:
Dividends
from
investment
income—net
(0.11)
Net
asset
value,
end
of
period
49.77
Market
price,
end
of
period
(c)
49.77
Net
Asset
Value
Total
Return
(%)
(d)
(0.23)
Market
Price
Total
Return
(%)
(d)
(0.24)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.12
(e)
Ratio
of
net
investment
income
to
average
net
assets
0.55
(e)
Portfolio
Turnover
Rate
(f)
16.00
Net
Assets,
end
of
period
($
x
1,000)
27,376
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
The
mean
between
the
last
bid
and
ask
prices.
(d)
Net
asset
value
total
return
is
calculated
assuming
an
initial
investment
made
at
the
net
asset
value
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
net
asset
value
during
the
period,
and
redemption
at
net
asset
value
on
the
last
day
of
the
period.
Net
asset
value
total
return
includes
adjustments
in
accordance
with
accounting
principles
generally
accepted
in
the
United
States
of
America
and
as
such,
the
net
asset
value
for
financial
reporting
purposes
and
the
returns
based
upon
those
net
asset
values
may
differ
from
the
net
asset
value
and
returns
for
shareholder
transactions.
Market
price
total
return
is
calculated
assuming
an
initial
investment
made
at
the
market
price
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
market
price
during
the
period,
and
sale
at
the
market
price
on
the
last
day
of
the
period.
Total
investment
returns
calculated
for
a
period
of
less
than
one
year
are
not
annualized.
(e)
Annualized.
(f)
Portfolio
turnover
rate
is
not
annualized
for
periods
less
than
one
year,
if
applicable,
and
does
not
include
securities
received
or
delivered
from
processing
creations
or
redemptions.
12
NOTES
TO
FINANCIAL
STATEMENTS
NOTE
1—Organization:
BNY
Mellon
ETF
Trust
(the
“Trust”) is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-end
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
thirteen
series,
including
BNY
Mellon
Ultra
Short
Income
ETF
(the
“fund”).
The
fund
had
no
operations
until
August
9,
2021
(commencement
of
operations),
other
than
matters
relating
to
its
organization
and
registration
under
the
Act.
The
investment
objective
of
the
fund
is
to
seek
high
current
income
consistent
with
the
maintenance
of
liquidity
and
low
volatility
of
principal.
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
a
wholly-owned
subsidiary
of
The
Bank
of
New
York
Mellon
Corporation
(“BNY
Mellon”),
serves
as
the
fund’s
investment
adviser.
Dreyfus
Cash
Investment
Strategies,
a
division
of
Mellon
Investments
Corporation
(the
“Sub-Adviser”),
a
wholly-owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-investment
adviser.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a
wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“fund’s
Shares.”
The
fund’s
Shares
are
listed
and
traded
on
NYSE
Arca,
Inc.
The
market
price
of
each
Share
may
differ
to
some
degree
from
the
fund’s
net
asset
value
(“NAV”).
Unlike
conventional
mutual
funds,
the
fund
issues
and
redeems
Shares
on
a
continuous
basis,
at
NAV,
only
in
a
large
specified
number
of
Shares,
each
called
a
“Creation
Unit.”
Creation
Units
are
issued
and
redeemed
principally
in
exchange
for
the
deposit
or
delivery
of
a
basket
of
securities.
Except
when
aggregated
in
Creation
Units
by
Authorized
Participants,
the
Shares
are
not
individually
redeemable
securities
of
the
fund.
Individual
fund
Shares
may
only
be
purchased
and
sold
on
the
NYSE
Arca,
Inc.,
other
national
securities
exchanges,
electronic
crossing
networks
and
other
alternative
trading
systems
through
your
broker-dealer
at
market
prices.
Because
fund
Shares
trade
at
market
prices
rather
than
at
NAV,
fund
Shares
may
trade
at
a
price
greater
than
NAV
(premium)
or
less
than
NAV
(discount).
When
buying
or
selling
Shares
in
the
secondary
market,
you
may
incur
costs
attributable
to
the
difference
between
the
highest
price
a
buyer
is
willing
to
pay
to
purchase
Shares
of
the
fund
(bid)
and
the
lowest
price
a
seller
is
willing
to
accept
for
Shares
of
the
fund
(ask).
NOTE
2—Significant
Accounting
Policies:
The
Financial
Accounting
Standards
Board
(“FASB”)
Accounting
Standards
Codification
(“ASC”)
is
the
exclusive
reference
of
authoritative
U.S.
generally
accepted
accounting
principles
(“GAAP”)
recognized
by
the
FASB
to
be
applied
by
nongovernmental
entities.
Rules
and
interpretive
releases
of
the
SEC
under
authority
of
federal
laws
are
also
sources
of
authoritative
GAAP
for
SEC
registrants. The
fund’s
an
investment
company
and
applies
the
accounting
and
reporting
guidance
of
the
FASB
ASC
Topic
946
Financial
Services-
Investment
Companies. The
fund’s
financial
statements
are
prepared
in
accordance
with
GAAP,
which
may
require
the
use
of
management
estimates
and
assumptions.
Actual
results
could
differ
from
those
estimates.
The
Trust
accounts
separately
for
the
assets,
liabilities
and
operations
of
each
series.
Expenses
directly
attributable
to
each
series
are
charged
to
that
series’
operations;
expenses
which
are
applicable
to
all
series
are
allocated
among
them
on
a
pro
rata
basis.
The
Trust
enters
into
contracts
that
contain
a
variety
of
indemnifications.
The
fund’s
maximum
exposure
under
these
arrangements
is
unknown.
The
fund
does
not
anticipate
recognizing
any
loss
related
to
these
arrangements.
(a)
Portfolio
valuation:
The
fair
value
of
a
financial
instrument
is
the
amount
that
would
be
received
to
sell
an
asset
or
paid
to
transfer
a
liability
in
an
orderly
transaction
between
market
participants
at
the
measurement
date
(i.e.,
the
exit
price).
GAAP
establishes
a
fair
value
hierarchy
that
prioritizes
the
inputs
of
valuation
techniques
used
to
measure
fair
value.
This
hierarchy
gives
the
highest
priority
to
unadjusted
quoted
prices
in
active
markets
for
identical
assets
or
liabilities
(Level
1
measurements)
and
the
lowest
priority
to
unobservable
inputs
(Level
3
measurements).
Additionally,
GAAP
provides
guidance
on
determining
whether
the
volume
and
activity
in
a
market
has
decreased
significantly
and
whether
such
a
decrease
in
activity
results
in
transactions
that
are
not
orderly.
GAAP
requires
enhanced
disclosures
around
valuation
inputs
and
techniques
used
during
annual
and
interim
periods.
Various
inputs
are
used
in
determining
the
value
of
the
fund’s
investments
relating
to
fair
value
measurements.
These
inputs
are
summarized
in
the
three
broad
levels
listed
below:
Level
1
—
unadjusted
quoted
prices
in
active
markets
for
identical
investments.
Level
2
—
other
significant
observable
inputs
(including
quoted
prices
for
similar
investments,
interest
rates,
prepayment
speeds,
credit
risk,
etc.).
Level
3
—
significant
unobservable
inputs
(including
the
fund’s
own
assumptions
in
determining
the
fair
value
of
investments).
The
inputs
or
methodology
used
for
valuing
securities
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
those
securities.
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value
and
are
generally
categorized
within
Level 1
of
the
fair
value
hierarchy.
13
Investments
in
debt
securities
excluding
short-term
investments
(other
than
U.S.
Treasury
Bills),
are
valued
each
business
day
by
one
or
more
independent
pricing
services
(each,
a
“Service”)
approved
by
the
Trust
Board
of
Trustees
(the
“Board”).
Investments
for
which
quoted
bid
prices
are
readily
available
and
are
representative
of
the
bid
side
of
the
market
in
the
judgment
of
a
Service
are
valued
at
the
mean
between
the
quoted
bid
prices
(as
obtained
by
a
Service
from
dealers
in
such
securities)
and
asked
prices
(as
calculated
by
a
Service
based
upon
its
evaluation
of
the
market
for
such
securities).
Securities
are
valued
as
determined
by
a
Service,
based
on
methods
which
include
consideration
of
the
following:
yields
or
prices
of
securities
of
comparable
quality,
coupon,
maturity
and
type;
indications
as
to
values
from
dealers;
and
general
market
conditions.
Overnight
and
certain
other
short-term
debt
instruments
(excluding
U.S.
Treasury
Bills)
will
be
valued
by
the
amortized
cost
method,
which
approximates
value,
unless
a
Service
provides
a
valuation
for
such
security
or,
in
the
opinion
of
the
Board
or
a
committee
or
other
persons
designated
by
the
Board,
the
amortized
cost
method
would
not
represent
fair
value. These
securities
are
generally
categorized
within
Level
2
of
the
fair
value
hierarchy.
Each
Service
and
independent
valuation
firm
is
engaged
under
the
general
oversight
of
the
Board.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
accurately
fair
value,
such
as
when
the
value
of
a
security
has
been
significantly
affected
by
events
after
the
close
of
the
exchange
or
market
on
which
the
security
is
principally
traded
(for
example,
a
foreign
exchange
or
market),
but
before
the
fund
calculates
its
net
asset
value,
the
fund
may
value
these
investments
at
fair
value
as
determined
in
accordance
with
the
procedures
approved
by
the
Board.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
The
table
below
summarizes
the
inputs
used
as
of December
31,
2021
in
valuing
the
fund’s
investments:
Fair
Value
Measurements
(b)
Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
(c)
Affiliated
issuers:
Investments
in
other
investment
companies
advised
by
the
Adviser
are
defined
as
“affiliated”
under
the
Act.
(d)
Risk:
Certain
events
particular
to
the
industries
in
which
the
fund’s
investments
conduct
their
operations,
as
well
as
general
economic,
political
and
public
health
conditions,
may
have
a
significant
negative
impact
on
the
investee’s
operations
and
profitability.
In
addition,
turbulence
in
financial
markets
and
reduced
liquidity
in
equity,
credit
and/or
fixed
income
markets
may
negatively
affect
many
issuers,
which
could
adversely
affect
each
fund.
Global
economies
and
financial
markets
are
becoming
increasingly
interconnected,
and
conditions
and
events
in
one
country,
region
or
financial
market
may
adversely
impact
issuers
in
a
different
country,
region
or
financial
market.
These
risks
may
be
magnified
if
certain
events
or
developments
adversely
interrupt
the
global
supply
chain;
in
these
and
other
circumstances,
such
risks
might
affect
companies
world-wide.
Recent
examples
include
pandemic
risks
related
to
COVID-19
and
aggressive
measures
taken
world-wide
in
response
by
governments,
including
closing
borders,
restricting
international
and
domestic
travel,
and
the
imposition
of
prolonged
quarantines
of
large
populations,
and
by
businesses,
including
changes
to
operations
and
reducing
staff.
The
effects
of
COVID-19
have
contributed
to
increased
volatility
in
global
markets
and
will
likely
affect
certain
countries,
companies,
industries
and
market
sectors
more
dramatically
than
others.
The
COVID-19
pandemic
has
had,
and
any
other
outbreak
of
an
infectious
disease
or
other
serious
public
health
concern
could
have,
a
significant
negative
impact
on
economic
and
market
conditions
and
could
trigger
a
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Asset-Backed
Securities
—
2,554,338
—
2,554,338
Commercial
Paper
—
13,933,717
—
13,933,717
Corporate
Bonds
—
10,336,666
—
10,336,666
Negotiable
Bank
Certificates
of
Deposit
—
499,560
—
499,560
Investment
Companies
11,989
—
—
11,989
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
14
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
prolonged
period
of
global
economic
slowdown.
To
the
extent
the
fund
may
overweight
its
investments
in
certain
countries,
companies,
industries
or
market
sectors,
such
positions
will
increase the
fund’s
exposure
to
risk
of
loss
from
adverse
developments
affecting
those
countries,
companies,
industries
or
sectors.
The
fund
invests
in
debt
securities.
Failure
of
an
issuer
of
the
debt
securities
to
make
timely
interest
or
principal
payments,
or
a
decline
or
the
perception
of
a
decline
in
the
credit
quality
of
a
debt
security,
can
cause
the
debt
security’s
price
to
fall,
potentially
lowering
the
fund’s
share
price.
In
addition,
the
value
of
debt
securities
may
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
issuer,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates
or
adverse
investor
sentiment.
They
may
also
decline
because
of
factors
that
affect
a
particular
industry.
(e)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions
payable
to
shareholders
are
recorded
by
the
fund
on
the
ex-dividend
date.
The
fund
normally
declares
and
pays
dividends
from
investment
income-net
monthly.
Income
dividends
for
the
fund
may
vary
significantly
from
period
to
period. Dividends
from
net
realized
capital
gains,
if
any,
are
normally
declared
and
paid
annually,
but
the
fund
may
make
distributions
on
a
more
frequent
basis
to
comply
with
the
distribution
requirements
of
the
Internal
Revenue
Code
of
1986,
as
amended
(the
“Code”).
To
the
extent
that
net
realized
capital
gains
can
be
offset
by
capital
loss
carryovers
of
a
fund,
it
is
the
policy
of
the
fund
not
to
distribute
such
gains.
Income
and
capital
gain
distributions
are
determined
in
accordance
with
income
tax
regulations,
which
may
differ
from
GAAP.
On
December
28,
2021,
the
Board
declared
a
cash
dividend
of
$0.03132
per
share
from
investment
income-net,
payable
on
January
4,
2022
to
Common
shareholders
of
record
as
of
the
close
of
business
on
December
30,
2021.
The
ex-dividend
date
was
December
29,
2021.
(f)
Federal
income
taxes:
It
is
the
policy
of
the
fund
to
qualify
as
a
regulated
investment
company,
if
such
qualification
is
in
the
best
interests
of
its
shareholders,
by
complying
with
the
applicable
provisions
of
the
Code,
and
to
make
distributions
of
taxable
income
sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
For
federal
income
tax
purposes,
the
fund
is
treated
as
a
separate
entity
for
the
purpose
of
determining
such
qualification.
As
of
and
during
the period
ended December
31,
2021,
the
funds
did
not
have
any
liabilities
for
any
uncertain
tax
positions.
The
fund
recognizes
interest
and
penalties,
if
any,
related
to
uncertain
tax
positions
as
income
tax
expense
in
the
Statement
of
Operations.
During
the period
ended December
31,
2021,
the
fund
did
not
incur
any
interest
or
penalties.
(g)
New
Accounting
Pronouncement:
In
March
2020,
the
FASB
issued
Accounting
Standards
Update
2020-04,
Reference
Rate
Reform
(Topic
848):
Facilitation
of
the
Effects
of
Reference
Rate
Reform
on
Financial
Reporting
(“ASU
2020-04”),
and
in
January
2021,
the
FASB
issued
Accounting
Standards
Update
2021-01,
Reference
Rate
Reform
(Topic
848):
Scope
(“ASU
2021-
01”),
which
provides
optional,
temporary
relief
with
respect
to
the
financial
reporting
of
contracts
subject
to
certain
types
of
modifications
due
to
the
planned
discontinuation
of
the
London
Interbank
Offered
Rate
(“LIBOR”)
and
other
Interbank
Offered
Rate
(“IBOR”)-based
reference
rates
as
of
the
end
of
2021.
The
temporary
relief
provided
by
ASU
2020-04
and
ASU
2021-01 is
effective
for
certain
reference
rate-related
contract
modifications
that
occur
during
the
period
from
March
12,
2020
through
December
31,
2022.
Management
is
evaluating
the
impact
of
ASU
2020-04
and
ASU
2021-01 on
the
fund’s
investments,
derivatives,
debt
and
other
contracts
that
will
undergo
reference
rate-related
modifications
as
a
result
of
the
reference
rate
reform.
NOTE
3—Management
Fee,
Sub-Investment
Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Fees
payable
by
the
fund
pursuant
to
the
provisions
of
a
management
agreement
with
the
Adviser
are
payable
monthly,
computed
at
an
annual
rate of
0.12%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
fund’s
management
agreement
provides
that
the
Adviser
will
pay
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expenses,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
December
31,
2021,
there
were
no
reduction
in
expenses
pursuant
to
the
undertaking.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-Adviser,
the
Sub-Adviser
serves
as
the
fund’s
sub-investment
adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
sub-investment
adviser
a
monthly
fee
at
an
annual
percentage
of
the
value
of
the
fund's
average
daily
net
assets.
The
Adviser
has
obtained
an
exemptive
order
from
the
SEC
(the
“Order”),
upon
which
the
fund
may
rely,
to
use
a
manager
of
managers
approach
that
permits
the
Adviser,
subject
to
certain
conditions
and
approval
by
the
Board,
to
enter
into
and
materially
amend
sub-investment
advisory
agreements
with
one
or
more
sub-
investment
advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-investment
advisory
fee
paid
by
the
Adviser
to
a
sub-adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
15
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-
investment
advisory
fee
payable
by
the
Adviser
separately
to
a
sub-adviser
that
is
a
wholly-owned
subsidiary
(as
defined
in
the
1940
Act)
of
BNY
Mellon
in
documents
filed
with
the
SEC
and
provided
to
shareholders;
such
fees
are
to
be
aggregated
with
fees
payable
to
the
Adviser.
The
Adviser
has
ultimate
responsibility
(subject
to
oversight
by
the
Board)
to
supervise
any
sub-adviser
and
recommend
the
hiring,
termination,
and
replacement
of
any
sub-adviser
to
the
Board.
The
Adviser
will
pay
a
monthly
sub
advisory
fee
to
the
Sub-
Adviser
at
the
annual
rate
of
0.06%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
adviser,
and
not
the
fund,
pays
the
Sub-Adviser
fee
rate.
(b)
The
fund
has
an
arrangement
with
the
custodian
whereby
the
fund
will
receive
interest
income
or
be
charged
overdraft
fees
when
cash
balances
are
maintained.
For
financial
reporting
purposes,
the
fund
includes
this
interest
income
and
overdraft
fees,
if
any,
as
interest
income
in
the
Statement
of
Operations.
The
components
of
“Due
to
BNY
Mellon
Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fees
of $2,922.
(c)
Each
Board
member
serves
as
a
Board
member
of
the
fund
within
the
Trust.
Annual
retainer
fees
and
attendance
fees
are
allocated
to the
fund
based
on
net
assets.
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
(including
paydowns,
if
any)
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions, amounted
to $15,360,720
and
$1,839,309,
respectively.
At December
31,
2021,
accumulated
net
unrealized
depreciation on
investments
was
$125,776,
consisting
of
gross
unrealized
appreciation
of
$1,892
and
gross
depreciation
of
$127,668.
At
December
31,
2021,
the
cost
of
investments
for
federal
income
tax
purposes
was
substantially
the
same
as
the
cost
for
financial
reporting
purposes
(see
the
Statement
of
Investments).
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
in-
kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Other
Capital”
on
the
Statement
of
Changes
in
Net
Assets.
In-kind
Redemptions:
For
financial
reporting
purposes,
in-
kind
redemptions
are
treated
as
sales
of
securities
resulting
in
realized
capital
gains
or
losses
to
the
fund.
Because
such
gains
or
losses
are
not
taxable
to
the
fund
and
are
not
distributed
to
existing
fund
shareholders,
the
gains
or
losses
are
reclassified
from
accumulated
net
realized
gain
(loss)
to
paid-in
capital
at
the
end
of
the
fund’s
tax
year.
These
reclassifications
have
no
effect
on
net
assets
or
net
asset
value
per
share.
During
the
period
ended
December
31,
2021,
the
fund
had
no
in-kind
transactions.
16
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT
AND
SUB-
INVESTMENT
ADVISORY
AGREEMENTS
(Unaudited)
At
a
meeting
held
May
17,
2021,
the
Board
of
Trustees
of
the
Trust
(the
“Board”)
evaluated
proposals
to
approve
the
Management
Agreement
(the
“Agreement”)
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”)
pursuant
to
which
the
Adviser
will
provide
the
BNY
Mellon
Ultra
Short
Income
ETF
(the
“fund”),
which
commenced
operations
during
the
period
covered
by
this
Semiannual
Report,
with
investment
advisory
and
administrative
services,
and
the
Sub-
Investment
Advisory
Agreement
(together,
the
"Agreements"),
pursuant
to
which
Dreyfus
Cash
Investment
Strategies,
a
division
of
Mellon
Investments
Corporation
(the
"Sub-Adviser"),
an
affiliate
of
the
Adviser,
will
provide
day-to-day
management
of
the
fund’s
investments.
The
Board
was
advised
by
legal
counsel
throughout
the
process.
To
evaluate
the
Agreements,
the
Board
requested,
and
the
Adviser
and
Sub-Adviser
provided,
such
materials
as
the
Board,
with
the
advice
of
counsel,
deemed
reasonably
necessary.
In
deciding
whether
to
approve
the
Agreements,
the
Board
considered
various
factors,
including
the
(i)
nature,
extent
and
quality
of
services
expected
to
be
provided
by
the
Adviser
and
Sub-Adviser
under
each
respective
Agreement,
(ii)
fees
charged
to
comparable
funds,
(iii)
other
benefits
to
the
Adviser
and
Sub-
Adviser,
and
(iv)
extent
to
which
economies
of
scale
would
be
shared
as
the
fund
grows.
The
Board
considered
the
Agreements
for
the
fund
and
the
engagement
of
the
Adviser
and
the
Sub-
Adviser
separately.
Nature,
Extent
and
Quality
of
Services
The
Board
considered
the
nature,
extent
and
quality
of
services
expected
to
be
provided
by
the
Adviser
and
Sub-Adviser.
The
Board
reviewed
the
Agreements
and
the
Adviser’s
anticipated
responsibilities
of
investment
advisory
and
administrative
services
for
the
fund,
including
oversight
of
day-to-day
fund
operations,
fund
accounting,
administration,
and
assistance
in
meeting
legal
and
regulatory
requirements.
The
Board
considered
the
background
and
experience
of
the
Adviser
and
Sub-Adviser’s
senior
management,
including
those
individuals
responsible
for
portfolio
management
and
regulatory
compliance
of
the
fund.
The
Board
also
considered
the
Adviser’s
extensive
administrative,
accounting,
and
compliance
infrastructures,
as
well
as
the
Adviser’s
supervisory
activities
over
the
Sub-Adviser.
The
Board
appreciated
the
nature
of
the
fund
as
an
exchange-
traded
fund
and
the
experience
and
expertise
of
the
Sub-Adviser
with
exchange-traded
funds.
The
Board
considered
the
portfolio
management
resources,
structures
and
practices
of
the
Adviser
and
Sub-Adviser,
including
those
associated
with
monitoring
and
securing
the
fund’s
compliance
with
its
investment
objective
and
policy
and
with
applicable
laws
and
regulations.
The
Board
also
considered
information
about
the
Sub-Adviser’s
best
execution
procedures
and
overall
investment
management
business.
The
Board
looked
at
the
Adviser’s
general
knowledge
of
the
investment
management
business
and
that
of
its
affiliates,
including
the
Sub-
Adviser.
As
the
fund
had
not
yet
commenced
operations,
the
Board
was
not
able
to
review
the
fund’s
performance.
The
Board
discussed
with
representatives
of
the
Adviser
and
the
Sub-
Adviser
the
proposed
portfolio
management
team
and
the
investment
strategy
to
be
employed
in
the
management
of
the
fund's
assets.
The
Board
was
provided
with
relevant
composite
performance
information.
The
Board
considered
the
reputation
and
experience
of
the
Adviser
and
its
affiliates,
including
the
Sub-Adviser.
Fees
Charged
to
Comparable
Funds
The
Board
evaluated
the
fund’s
proposed
unitary
fee
through
review
of
comparative
information
with
respect
to
fees
paid
by
similar
funds
–
i.e.,
actively
managed
ultra
short
bond
exchange-traded
funds.
The
Board
reviewed
the
universe
of
similar
exchange-traded
funds
for
the
fund
based
upon
data
independently
obtained
from
Broadridge
Financial
Solutions,
Inc.
and
related
comparative
information
for
similar
exchange-
traded
funds.
The
Board
also
reviewed
the
estimated
expense
ratio
for
the
fund.
The
Board
considered
the
fee
to
be
paid
to
the
Sub-Adviser
in
relation
to
the
fee
to
be
paid
to
the
Adviser
by
the
fund
and
the
respective
services
to
be
provided
by
the
Sub-Adviser
and
the
Adviser.
The
Board
also
took
into
consideration
that
the
Sub-
Adviser's
fee
will
be
paid
by
the
Adviser
and
not
the
fund.
Other
Benefits
The
Board
also
considered
whether
the
Adviser,
Sub-Adviser
or
their
affiliates
benefited
in
other
ways
from
their
relationship
with
the
fund,
noting
that
neither
the
Adviser
nor
Sub-Adviser
maintains
soft-dollar
arrangements
in
connection
with
the
fund’s
brokerage
transactions.
Profitability
and
Economies
of
Scale
The
Board
reviewed
information
regarding
economies
of
scale
or
other
efficiencies
that
may
result
as
the
fund’s
assets
grow
in
size.
The
Board
noted
that
the
Agreement
did
not
provide
for
breakpoints
in
the
fund’s
advisory
fee
rate
as
assets
of
the
fund
increase.
However,
the
Board
further
noted
the
Adviser’s
assertion
that
future
economies
of
scale
(among
several
factors)
had
been
taken
into
consideration
for
the
fund
by
fixing
relatively
low
advisory
fees,
effectively
sharing
the
benefits
of
lower
fees
with
the
fund
from
the
time
of
its
inception.
The
Adviser
also
asserted
that
one
of
the
benefits
of
the
unitary
fee
was
to
provide
an
unvarying
expense
structure,
which
could
be
lost
or
diluted
with
the
addition
of
breakpoints.
The
Board
noted
that,
because
the
fund
is
new,
there
are
no
economies
of
scale
to
share,
but
it
intends
to
continue
to
monitor
fees
as
the
fund
grows
in
size
and
to
the
extent
in
the
future
it
were
determined
that
material
economies
of
scale
had
not
been
shared
with
the
fund,
the
Board
would
seek
to
have
those
economies
of
scale
shared
with
the
fund
in
connection
with
future
renewals.
As
the
fund
had
not
yet
commenced
operations,
the
Adviser’s
representatives
were
not
able
to
review
the
dollar
amount
of
expenses
allocated
and
profit
received
by
the
Adviser
or
Sub-Adviser.
17
Conclusion
After
weighing
the
foregoing
factors,
none
of
which
was
dispositive
in
itself
and
may
have
been
weighed
differently
by
each
Trustee,
the
Board
approved
the
Agreements
for
the
fund.
The
Board’s
conclusions
with
respect
to
the
factors
were
as
follows:
(a)
the
nature
and
extent
of
the
services
expected
to
be
provided
by
the
Adviser
and
Sub-Adviser
with
respect
to
the
fund
was
appropriate;
(b)
the
Adviser’s
unitary
fee
for
the
fund,
considered
in
relation
to
services
expected
to
be
provided
and
in
relation
to
fees
charged
to
comparable
funds,
was
fair
and
reasonable;
and
(c)
any
additional
potential
benefits
to
the
Adviser,
Sub-Adviser
or
their
affiliates
were
not
of
a
magnitude
to
materially
affect
the
Board’s
conclusions.
For
More
Information
2022
BNY
Mellon
Securities
Corporation
4862SA1221
Telephone
Call
your
financial
representative
or
1-833-ETF-BNYM
(383-2696)
(inside
the
U.S.
only)
Mail
BNY
Mellon
ETF
Trust,
240
Greenwich
Street,
New
York,
New
York
10286
E-Mail
Send
your
request
to
info@bnymellon.com
Internet
Information
can
be
viewed
online
or
downloaded
at
www.im.bnymellon.com
BNY
Mellon
ETF
Trust
discloses,
at
www.im.bnymellon.com
,
the
identities
and
quantities
of
the
securities
held
by
each
fund
daily.
Each
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
“
SEC
”
)
for
the
first
and
third
quarters
of
each
fiscal
year
on
Form
N-PORT.
Each
fund
’
s
Forms
N-PORT
are
available
on
the
SEC
’
s
website
at
www.sec.gov
.
Additionally,
each
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://
im.bnymellon.com/etfliterature
.
Each
fund
’
s
complete
schedule
of
portfolio
holdings,
as
filed
on
Form
N-PORT,
can
also
be
obtained
without
charge,
upon
request,
by
calling
1-833-383-2696.
A
description
of
the
policies
and
procedures
that
each
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
each
fund
voted
these
proxies
for
the
most
recent
12-month
period
ended
June
30
is
available
at
www.
im.bnymellon.com
and
on
the
SEC’s
website
at
www.sec.gov
.
The
description
of
the
policies
and
procedures
is
also
available
without
charge,
upon
request,
by
calling
1-833-383-2696.
BNY
Mellon
ETF
Trust
Custodian
c/o
BNY
Mellon
ETF
Investment
Adviser,
LLC
240
Greenwich
Street
New
York,
NY
10286
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Adviser
Transfer
Agent
&
Dividend
Disbursing
Agent
BNY
Mellon
ETF
Investment
Adviser,
LLC
201
Washington
Street
Boston,
MA
02108
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Sub-Adviser
Distributor
Dreyfus
Cash
Investment
Strategies,
a
division
of
Mellon
Investments
Corporation
BNY
Mellon
Center
One
Boston
Place
Boston,
MA
02108
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
Ultra
Short
Income
ETF
BKUI
Item 1. Reports to Stockholders (cont.).
(b) Not applicable.
Item 2. Code of Ethics.
Not applicable.
Item 3. Audit Committee Financial Expert.
Not applicable.
Item 4. Principal Accountant Fees and Services.
Not applicable.
Item 5. Audit Committee of Listed Registrants.
Not applicable.
Item 6. Investments.
(a) The Schedule of Investments in securities of unaffiliated issuers as of the close of the Reporting Period is included as part of the report to shareholders filed under Item 1(a) of this Form N-CSR.
(b) Not applicable.
Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.
Not applicable.
Item 8. Portfolio Managers of Closed-End Management Investment Companies.
Not applicable.
Item 9. Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.
Not applicable.
Item 10. Submission of Matters to a Vote of Security Holders.
There have been no material changes to the procedures by which the shareholders may recommend nominees to the Registrant’s Board of Trustees, where those changes were implemented after the Registrant last provided disclosure in response to the requirements of Item 407(c)(2)(iv) of Regulation S-K (17 CFR 229.407) (as required by Item 22(b)(15) of Schedule 14A (17 CFR 240.14a-101)), or this Item.
Item 11. Controls and Procedures.
(a)
The Registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the Registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”) (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d-15(b)).
(b)
There were no changes in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d))) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.
Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.
Not applicable.
Item 13. Exhibits.
(a)(1) Not applicable.
(a)(2)
(a)(3) Not applicable.
(a)(4) Not applicable.
(b)
Certifications pursuant to Rule 30a-2(b) under the 1940 Act and Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
(Registrant) BNY Mellon ETF Trust
By (Signature and Title)* /s/ David J. DiPetrillo
David DiPetrillo, President
(Principal Executive Officer)
Date 02/22/2022
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
By (Signature and Title)* /s/ David J. DiPetrillo
David DiPetrillo, President
David DiPetrillo, President
(Principal Executive Officer)
Date 02/22/2022
By (Signature and Title)* /s/ James Windels
James Windels, Treasurer
James Windels, Treasurer
(Principal Financial and Accounting Officer)
Date 02/22/2022
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Print the name and title of each signing officer under his or her signature.