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)
(Exact name of registrant as specified in charter)
240 Greenwich Street
New York, New York 10286
(Address of principal executive offices) (Zip code)
(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: February 28
Date of reporting period: August 31, 2023
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 Innovators ETF
BNY Mellon Women’s Opportunities ETF
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
SEMI-ANNUAL
REPORT
August
31,
2023
BNY
Mellon
Innovators
ETF
Contents
The
Fund
Save
time.
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paper.
View
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next
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report
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as
soon
as
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available.
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into
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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
Discussion
of
Fund
Performance
3
Understanding
Your
Fund’s
Expenses
7
Statement
of
Investments
8
Statement
of
Assets
and
Liabilities
11
Statement
of
Operations
12
Statement
of
Changes
in
Net
Assets
13
Financial
Highlights
14
Notes
to
Financial
Statements
15
Information
About
the
Approval
of
the
Fund’s
Management,
Sub-Advisory
and
Sub-Sub
Advisory
Agreements
23
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
May
17,
2023,
the
fund’s
inception
1
,
through
August
31,
2023,
as
provided
by
John
Porter
and
Edward
Walter,
portfolio
managers
employed
by
the
fund’s
sub-adviser,
Newton
Investment
Management
North
America,
LLC.
Market
and
Fund
Performance
Overview
For
the
period
from
May
17,
2023,
the
fund’s
inception,
through
August
31,
2023,
the
BNY
Mellon
Innovators
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
8.03%.
2
In
comparison,
the
fund’s
benchmark,
the
Russell
3000
®
Growth
Index
(the
“Index”),
produced
a
total
return
of
13.30%
for
the
same
period.
3
Equities
gained
ground
during
the
reporting
period
as
inflationary
pressures
eased,
the
U.S.
Federal
Reserve
(the
“Fed”)
reduced
the
pace
of
interest-rate
hikes,
and
economic
growth
remained
positive.
The
fund
underperformed
the
Index
largely
due
to
overweight
exponent
sure
to
the
lagging
health
care
sector.
The
Fund’s
Investment
Approach
The
fund
seeks
long-term
capital
growth.
To
pursue
its
goal,
the
fund
normally
invests
principally
in
equity
securities
of
U.S.
innovation-driven
companies.
The
fund’s
sub-
adviser,
Newton
Investment
Management
North
America
LLC
(“NIMNA”),
an
affiliate
of
the
Adviser,
considers
innovation-driven
companies
to
be
(i)
leading
edge
companies
that,
through
their
intellectual
property,
provide
ground-breaking
and/or
innovative
products
and
services
that
can
be
disruptive
and
transformative
to
existing
business
models
and
practices
and
(ii)
business
enterprises
that
are
positively
impacted
by
the
transformation
of
their
business
models
and
practices
through
the
use
of
such
products
or
services.
NIMNA
employs
a
growth-oriented
investment
style
in
managing
the
fund’s
portfolio
and
focuses
on
individual
stock
selection.
NIMNA
selects
stocks
for
the
fund
by
using
fundamental
research
complemented
by
“thematic
insights”
to
identify
companies
that
it
considers
to
have
attractive
investment
characteristics,
such
as
strong
business
models
and
competitive
positions,
attractive
valuation,
solid
cash
flows
and
balance
sheets,
high
quality
management
and
high
sustainable
earnings
growth.
The
combination
of
fundamental
research
and
thematic
insights
enables
NIMNA
to
better
understand
the
drivers
and
beneficiaries
of
innovation
and
disruption
as
well
as
structural
headwinds
and
tailwinds
for
a
company’s
overall
business.
Thematic
insights
refer
to
overarching
or
recurring
themes,
trends
or
shifts
that
emerge
from
NIMNA’s
research
and
analysis
of
global
economic
information.
Equities
Advance
Despite
Macroeconomic
Concerns
Market
sentiment
proved
generally
positive
during
the
reporting
period,
with
hopes
for
continued
economic
growth
outweighing
concerns
regarding
persistently
high
levels
of
inflation
and
the
impact
of
central
bank
interest-rate
hikes
designed
to
curb
inflation.
In
May
2023,
as
the
period
began,
U.S.
inflation
averaged
4.05%
on
an
annualized
basis,
down
from
the
9.1%
peak
set
in
June
2022
but
above
the
target
of
2%
set
by
the
Fed.
The
benchmark
federal
funds
rate
stood
at
5.00%–5.25%,
the
highest
level
since
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
2007.
During
the
reporting
period,
inflation
fell
below
4%,
and
the
Fed
raised
rates
by
an
additional
0.25%,
with
few,
if
any,
additional
increases
expected
by
the
market.
Although
U.S.
economic
growth
and
corporate
profits
showed
signs
of
moderating,
indications
remained
broadly
positive,
supported
by
robust
consumer
spending,
rising
wages
and
low
levels
of
unemployment.
These
encouraging
economic
trends
eased
concerns
that
high
rates
might
tip
the
economy
into
a
recession.
Accordingly,
while
equity
markets
dipped
or
spiked
in
response
to
the
economic
news
of
the
day,
stocks
trended
higher
on
balance,
largely
driven
by
momentum
factors
among
large-cap
issues
and
further
bolstered
by
the
improving
performance
of
value
factors.
Stock
Selections
Detract
from
Relative
Performance
Given
the
prevailing
environment
of
high
interest
rates
and
tightening
credit
conditions,
the
fund
emphasized
investments
in
well-capitalized
companies
with
sufficient
capital
to
finance
operations.
We
identified
a
relatively
large
number
of
innovative
companies
meeting
our
investment
criteria
in
the
health
care
sector,
many
areas
of
which
appeared
well
positioned
to
see
increased
revenue
streams
in
the
wake
of
the
COVID-19
pandemic.
However,
health
care
stocks
lagged
the
Index
as
investors
flocked
to
mega-
cap,
growth-oriented
names
with
exposure
to
developments
in
artificial
intelligence
(“AI”).
Many
of
the
fund’s
most
significant
underperforming
holdings
were
in
the
development-stage
biotechnology
space,
where
even
short-term
setbacks
in
the
drug
development
process
were
harshly
punished
by
the
market.
Notable
underperformers
included
Sarepta
Therapeutics,
Inc.
and
Denali
Therapeutics,
Inc.,
both
of
which
faced
drug
approval
concerns,
and
Prothena
Corp.
PLC
and
Keros
Therapeutics,
Inc.,
which
saw
the
emergence
of
potential
competition
from
drugs
under
development
by
larger
pharmaceutical
firms.
In
each
case,
our
research
reaffirmed
our
initial
investment
thesis,
leading
us
to
maintain
the
fund’s
positions.
Other
health
care
sector
underperformers
included
device
companies,
such
as
Inspire
Medical
Systems,
Inc.,
Outset
Medical,
Inc.
and
DexCom,
Inc.,
each
of
which
saw
shares
decline
in
the
face
of
potential
business
headwinds.
Again,
in
each
case,
our
research
indicated
that
the
companies’
business
prospects
remained
sound,
and
market
reactions
were
overblown.
The
fund’s
relative
performance
also
suffered
due
to
declines
in
a
small
number
of
specialty
retail
holdings,
including
international
luxury
fashion
retailer
Farfetch
Ltd.,
which
experienced
negative
impacts
from
slowing
consumer
spending,
and
exercise
equipment
company
Peloton
Interactive,
Inc.,
which
lost
ground
due
to
disappointing
corporate
execution
and
changing
post-pandemic
exercise
habits.
On
the
positive
side,
the
fund’s
relative
returns
benefited
from
several
relatively
strong
individual
stock
selections.
Top
performers
included
oil
and
gas
drilling
and
wellhead
equipment
maker
Cactus,
Inc.,
which
benefited
from
cutting-edge
product
design
and
rising
petroleum
prices;
semiconductor
maker
NVIDIA
Corp.,
which
posted
much
better-than-expected
financial
results
due
to
strong
demand
for
AI-related
chips;
and
database
company
MongoDB,
Inc.,
which
also
experienced
gains
related
to
the
AI
5
trend.
Relative
performance
further
benefited
from
the
fund’s
underweight
exposure
to
productivity
software
and
cloud
computing
company
Microsoft
Corp.,
which
trailed
the
Index.
From
a
sector
perspective,
energy
provided
the
strongest
relative
returns,
while
lack
of
exposure
to
some
consumer
staples
industries,
such
as
distribution,
household
products
and
beverages,
further
bolstered
performance.
Maintaining
a
Cautiously
Optimistic
Outlook
While
headline
inflation
is
falling
from
peak
levels,
as
of
August
31,
2023,
core
inflation
remains
stickier
than
investors
had
anticipated
in
many
markets.
With
the
Fed
currently
seen
as
poised
to
keep
interest
rates
elevated
for
longer
than
previously
expected,
the
real
economy
remains
vulnerable
as
the
impacts
of
past
rate
increases
work
their
way
through
the
system.
Accordingly,
we
remain
watchful
of
the
timing
and
extent
of
any
economic
weakness.
However,
structural
demand
trends
remain
in
place
as
many
global
transitions
continue
apace,
supported
in
some
cases
by
government
stimulus
and
support.
Against
this
backdrop,
we
maintain
our
emphasis
on
well-capitalized,
innovative
companies
exposed
to
resilient,
long-term
business
trends.
As
of
August
31,
2023,
we
continue
to
find
a
relatively
large
number
of
such
companies
in
the
health
care
sector,
where
the
successful
development
of
a
key
new
drug
or
device
can
position
a
company
to
dominate
a
sizeable
market.
We
are
also
finding
substantial
opportunities
in
a
variety
of
areas,
such
as
information
technology
and
consumer
products
and
services,
where
far-reaching
AI
applications
can
enable
companies
to
add
value
and
transform
the
competitive
landscape.
September
15,
2023
1
The
inception
date
is
the
first
date
the
fund
was
available
on
The
NASDAQ
Stock
Market
LLC.
2
Total
return
includes
reinvestment
of
dividends
and
any
capital
gains
paid.
A
fund’s
net
asset
value
(NAV)
is
the
sum
of
all
its
assets
less
any
liabilities,
divided
by
the
number
of
shares
outstanding.
ETFs
are
bought
and
sold
at
market
prices,
not
NAV,
therefore
an
investor’s
return
at
market
price
may
differ
from
NAV.
Past
performance
is
no
guarantee
of
future
results.
Share
price,
yield
and
investment
return
fluctuate
such
that
upon
redemption,
fund
shares
may
be
worth
more
or
less
than
their
original
cost.
3
Source:
Lipper
Inc.
—
The
Russell
3000
®
Growth
Index
measures
the
performance
of
the
broad
growth
segment
of
the
U.S.
equity
universe.
It
includes
those
Russell
3000
®
companies
with
relatively
higher
price-to-book
ratios,
higher
forecasted
growth
rates
and
higher
sales
per
share
historical
growth.
The
index
is
completely
reconstituted
annually
to
ensure
new
and
growing
equities
are
included
and
that
the
represented
companies
continue
to
reflect
growth
characteristics.
Investors
cannot
invest
directly
in
any
index.
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.
Equities
are
subject
generally
to
market,
market
sector,
market
liquidity,
issuer
and
investment
style
risks,
among
other
factors,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
Small
and
midsized
company
stocks
tend
to
be
more
volatile
and
less
liquid
than
larger
company
stocks
as
these
companies
are
less
established
and
have
more
volatile
earnings
histories.
The
healthcare
sector
is
subject
to
government
regulation
and
reimbursement
rates,
as
well
as
government
approval
of
products
and
services,
which
could
have
a
significant
effect
on
price
and
availability.
Furthermore,
the
types
of
products
or
services
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
6
produced
or
provided
by
healthcare
companies
quickly
can
become
obsolete.
In
addition,
companies
in
the
healthcare
sector
can
be
significantly
affected
by
patent
expirations,
pricing
pressure,
and
product
liability
claims.
The
information
technology
sector
has
been
among
the
most
volatile
sectors
of
the
stock
market.
Information
technology
companies
involve
greater
risk
because
their
revenue
and/or
earnings
tend
to
be
less
predictable
(and
some
companies
may
be
experiencing
significant
losses)
and
their
share
prices
tend
to
be
more
volatile.
Certain
information
technology
companies
may
have
limited
product
lines,
markets
or
financial
resources,
or
may
depend
on
a
limited
management
group.
In
addition,
these
companies
are
strongly
affected
by
worldwide
technological
developments,
and
their
products
and
services
may
not
be
economically
successful
or
may
quickly
become
outdated.
Investor
perception
may
play
a
greater
role
in
determining
the
day-to-day
value
of
information
technology
stocks
than
it
does
in
other
sectors.
Fund
investments
may
decline
dramatically
in
value
if
anticipated
products
or
services
are
delayed
or
canceled.
The
fund
is
non-diversified,
which
means
that
the
fund
may
invest
a
relatively
high
percentage
of
its
assets
in
a
limited
number
of
issuers.
Therefore,
the
fund’s
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
7
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
assuming
a
hypothetical
5%
annualized
return,
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.
For
the
six
months
ended
August
31,
2023
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
period
May
18,
2023
(commencement
of
operations)
to
August
31,
2023.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
106/366
(to
reflect
the
actual
days
in
the
period).
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
184/366
(to
reflect
the
one-half
period).
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)
1,000.00
1,000.00
1,080.30
1,022.62
1.51
2.54
0.50
STATEMENT
OF
INVESTMENTS
August
31,
2023
(Unaudited)
8
Description
Shares
Value
($)
Common
Stocks
–
99.7%
Capital
Goods
–
1.9%
AZEK
Co.,
Inc.
(The)
(a)
6,111
207,835
Consumer
Discretionary
Distribution
&
Retail
–
1.3%
Chewy,
Inc.,
Class
A
(a)
2,969
71,197
Farfetch
Ltd.,
Class
A
(a)
24,745
70,523
141,720
Consumer
Durables
&
Apparel
–
5.0%
Garmin
Ltd.
981
104,006
Lululemon
Athletica
,
Inc.
(a)
678
258,494
Peloton
Interactive,
Inc.,
Class
A
(a)
28,280
180,426
542,926
Consumer
Services
–
2.9%
Airbnb,
Inc.,
Class
A
(a)
1,398
183,907
DraftKings
,
Inc.,
Class
A
(a)
4,416
130,934
314,841
Energy
–
3.8%
Cactus,
Inc.,
Class
A
7,721
411,838
Financial
Services
–
4.8%
Ares
Management
Corp.,
Class
A
3,034
313,837
Block,
Inc.
(a)
3,496
201,545
515,382
Food,
Beverage
&
Tobacco
–
2.9%
Freshpet
,
Inc.
(a)
3,150
237,857
Vital
Farms,
Inc.
(a)
6,799
80,092
317,949
Health
Care
Equipment
&
Services
–
13.3%
Align
Technology,
Inc.
(a)
866
320,541
DexCom
,
Inc.
(a)
2,128
214,886
Inspire
Medical
Systems,
Inc.
(a)
790
179,235
Intuitive
Surgical,
Inc.
(a)
655
204,806
iRhythm
Technologies,
Inc.
(a)
1,200
124,044
Outset
Medical,
Inc.
(a)
7,531
102,497
Privia
Health
Group,
Inc.
(a)
5,953
156,266
TransMedics
Group,
Inc.
(a)
2,010
131,916
1,434,191
Materials
–
1.8%
Albemarle
Corp.
971
192,948
Media
&
Entertainment
–
12.3%
Alphabet,
Inc.,
Class
C
(a)
4,155
570,689
Atlanta
Braves
Holdings,
Inc.,
Class
C
(a)
78
2,874
Liberty
Media
Corp.-Liberty
Formula
One,
Class
C
(a)
2,727
187,590
Liberty
Media
Corp.-Liberty
Live,
Class
C
(a)
116
3,903
Netflix,
Inc.
(a)
742
321,791
9
Description
Shares
Value
($)
Common
Stocks
–
99.7%
(continued)
Media
&
Entertainment
–
12.3%
(continued)
Trade
Desk,
Inc.
(The),
Class
A
(a)
3,052
244,252
1,331,099
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
25.0%
10X
Genomics,
Inc.,
Class
A
(a)
2,882
149,432
Alnylam
Pharmaceuticals,
Inc.
(a)
1,045
206,722
Ascendis
Pharma
A/S,
ADR
(a)
2,229
218,487
BioMarin
Pharmaceutical,
Inc.
(a)
2,736
250,016
Crinetics
Pharmaceuticals,
Inc.
(a)
4,507
78,061
Cytokinetics,
Inc.
(a)
4,005
139,935
Denali
Therapeutics,
Inc.
(a)
5,092
117,574
Illumina,
Inc.
(a)
1,534
253,447
Insmed
,
Inc.
(a)
10,879
238,141
Keros
Therapeutics,
Inc.
(a)
2,185
76,715
Pacific
Biosciences
of
California,
Inc.
(a)
11,878
133,984
Prothena
Corp.
PLC
(a)
1,993
105,270
Repligen
Corp.
(a)
1,319
229,387
Sarepta
Therapeutics,
Inc.
(a)
1,577
190,833
Twist
Bioscience
Corp.
(a)
7,778
171,038
Xenon
Pharmaceuticals,
Inc.
(a)
3,666
142,901
2,701,943
Real
Estate
Management
&
Development
–
3.6%
CoStar
Group,
Inc.
(a)
4,684
384,041
Semiconductors
&
Semiconductor
Equipment
–
7.7%
NVIDIA
Corp.
1,673
825,709
Software
&
Services
–
13.4%
DoubleVerify
Holdings,
Inc.
(a)
5,288
178,787
Dynatrace
,
Inc.
(a)
4,290
206,778
MongoDB,
Inc.
(a)
536
204,377
Shopify,
Inc.,
Class
A
(a)
3,323
220,946
Snowflake,
Inc.,
Class
A
(a)
1,906
298,956
Twilio
,
Inc.,
Class
A
(a)
5,256
334,860
1,444,704
Total
Common
Stocks
(cost
$9,963,961)
10,767,126
Investment
Companies
–
0.3%
Registered
Investment
Companies
–
0.3%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.30%
(b)(c)
(cost
$35,460)
35,460
35,460
Total
Investments
(cost
$9,999,421)
100.0%
10,802,586
Cash
and
Receivables
(Net)
0.0%
548
Net
Assets
100.0%
10,803,134
ADR—American
Depositary
Receipt
STATEMENT
OF
INVESTMENTS
(continued)
10
See
Notes
to
Financial
Statements
(a)
Non-income
producing
security.
(b)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(c)
The
rate
shown
is
the
1-day
yield
as
of
August
31,
2023.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
August
31,
2023
are
as
follows:
Description
Value
5/18/23
1
Purchases
($)
2
Sales
($)
Value
8/31/23
Dividends/
Distributions
($)
Investment
Companies
–
0.3%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
357,967
(322,507)
35,460
1,712
Total
–
0.3%
—
357,967
(322,507)
35,460
1,712
1
Commencement
of
operations.
2
Includes
reinvested
dividends/distributions.
Portfolio
Summary
(Unaudited)
†
Value
(%)
Health
Care
38.3
Information
Technology
21.1
Communication
Services
12.3
Consumer
Discretionary
9.2
Financials
4.8
Energy
3.8
Real
Estate
3.6
Consumer
Staples
2.9
Industrials
1.9
Materials
1.8
Registered
Investment
Companies
0.3
100.0
†
Based
on
net
assets.
STATEMENT
OF
ASSETS
AND
LIABILITIES
August
31,
2023
(Unaudited)
11
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
–
Unaffiliated
issuers
9,963,961
10,767,126
Affiliated
issuers
35,460
35,460
Receivable
for
shares
of
Beneficial
Interest
subscribed
3,973
Dividends
receivable
1,101
10,807,660
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
4,526
4,526
Net
Assets
($)
10,803,134
Composition
of
Net
Assets
($):
Paid-in
capital
10,003,998
Total
distributable
earnings
(loss)
799,136
Net
Assets
($)
10,803,134
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
400,001
Net
asset
value
per
share
27.01
Market
price
per
share
27.04
STATEMENT
OF
OPERATIONS
For
the
Period
from
May
18,
2023
(commencement
of
operations)
to
August
31,
2023
(Unaudited)
12
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Unaffiliated
issuers
5,201
Affiliated
issuers
1,712
Total
Income
6,913
Expenses:
Management
fee—Note
3(a)
15,713
Total
Expenses
15,713
Net
Investment
(Loss)
(8,800)
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
4,771
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
803,165
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
807,936
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
799,136
STATEMENT
OF
CHANGES
IN
NET
ASSETS
13
See
Notes
to
Financial
Statements
For
the
Period
from
May
18,
2023
(a)
to
August
31,
2023
(Unaudited)
Operations
($):
Net
investment
(loss)
(8,800)
Net
realized
gain
(loss)
on
investments
4,771
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
803,165
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
799,136
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
10,000,025
Transaction
fees—Note
5
3,973
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
10,003,998
Total
Increase
(Decrease)
in
Net
Assets
10,803,134
Net
Assets
($):
Beginning
of
Period
—
End
of
Period
10,803,134
Changes
in
Shares
Outstanding:
Shares
sold
400,001
Net
Increase
(Decrease)
in
Shares
Outstanding
400,001
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
14
The
following
table
describes
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
May
18,
2023
(a)
to
August
31,
2023
(Unaudited)
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
25.00
Investment
Operations:
Net
investment
(loss)
(b)
(0.02)
Net
realized
and
unrealized
gain
(loss)
on
investments
2.02
Total
from
Investment
Operations
2.00
Transaction
fees
(b)
0.01
Net
asset
value,
end
of
period
27.01
Market
price,
end
of
period
(c)
27.04
Net
Asset
Value
Total
Return
(%)
(d)
8.03
(e)
Market
Price
Total
Return
(%)
(d)
8.16
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.50
(f)
Ratio
of
net
investment
(loss)
to
average
net
assets
(0.28)
(f)
Portfolio
Turnover
Rate
(g)
4.85
Net
Assets,
end
of
period
($
x
1,000)
10,803
(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)
The
net
asset
value
total
return
and
the
market
price
total
return
is
calculated
from
fund
inception.
The
inception
date
is
the
first
date
the
fund
was
available
on
The
NASDAQ
Stock
Market
LLC.
(f)
Annualized.
(g)
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.
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
15
NOTE
1—Organization:
BNY
Mellon
Innovators
ETF (the “fund”) is a
separate
non-diversified series
of
BNY
Mellon
ETF
Trust
(the
“Trust”),
which is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-ended
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
seventeen
series,
including
the
fund.
The
fund
had
no
operations
until
May
18,
2023
(commencement
of
operations),
other
than
matters
relating
to
its
organization
and
registration
under
the
Act.
The
commencement
of
operations
date
is
considered
to
be
the
date
that
the
fund
began
trading
in
the
secondary
market.
The
investment
objective
of
the
fund
is
to
seek
long-term
capital
growth.
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. Newton
Investment
Management
North
America,
LLC (the
“Sub-Adviser”
or
“NIMNA”),
an
indirect wholly-owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-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.
Effective
May
31,
2023,
the
Sub-Adviser
entered
into
a
sub-sub-investment
advisory
agreement
with
its
affiliate,
Newton
Investment
Management
Limited
(“NIM”),
to
enable
NIM
to
provide
certain
advisory
services
to
the
Sub-Adviser
for
the
benefit
of
the
fund,
including,
but
not
limited
to,
portfolio
management
services.
NIM
is
subject
to
the
supervision
of
the
Sub-Adviser
and
the
Adviser.
NIM
is
also
an
affiliate
of
the
Adviser.
NIM,
located
at
160
Queen
Victoria
Street,
London,
EC4V
4LA,
England,
was
formed
in
1978.
NIM
is
an
indirect
subsidiary
of
BNY
Mellon.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“fund’s
Shares.”
The
fund’s
Shares
are
listed
and
traded
on
The
NASDAQ
Stock
Market
LLC.
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
NASDAQ
Stock
Market
LLC,
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
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
16
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
is 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.).
17
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:
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
equity
securities,
including
ETFs
(but
not
including
investments
in
other
open-end
registered
investment
companies),
generally
are
valued
at
the
last
sales
price
on
the
day
of
valuation
on
the
securities
exchange
or
national
securities
market
on
which
such
securities
primarily
are
traded.
Securities
listed
on
the
National
Association
of
Securities
Dealers
Automated
Quotation
System
(“NASDAQ”)
for
which
market
quotations
are
available
will
be
valued
at
the
official
closing
price.
If
there
are
no
transactions
in
a
security,
or
no
official
closing
prices
for
a
NASDAQ
market-listed
security
on
that
day,
the
security
will
be
valued
at
the
average
of
the
most
recent
bid
and
asked
prices.
Bid
price
is
used
when
no
asked
price
is
available.
Open
short
positions
for
which
there
is
no
sale
price
on
a
given
day
are
valued
at
the
lowest
asked
price.
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value.
All
of
the
preceding
securities
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
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 August
31,
2023
in
valuing
the
fund’s
investments:
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
18
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
or
its
affiliates
are
defined
as
“affiliated”
under
the
Act.
(d)
Market
Risk:
The
value
of
the
securities
in
which
the
fund
invests
may
be
affected
by
political,
regulatory,
economic
and
social
developments,
and
developments
that
impact
specific
economic
sectors,
industries
or
segments
of
the
market.
The
value
of
a
security
may
also
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
company
or
industry,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
the
general
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates,
changes
to
inflation,
adverse
changes
to
credit
markets
or
adverse
investor
sentiment
generally.
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
the
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.
Innovation-Driven
Company
Risk:
There
can
be
no
assurance
that
a
company
identified
as
an
innovation-driven
company
by
NIMNA
will
ultimately
introduce
or
benefit
from
a
new
product
or
service
or
that
such
product
or
service
may
not
be
significantly
delayed
or
have
the
affect
NIMNA
anticipated.
The
returns
on
a
portfolio
of
securities
that
are
viewed
by
NIMNA
as
innovation-driven
companies
may
trail
the
returns
of
a
portfolio
that
is
not
limited
to
securities
of
innovation-driven
companies.
Investing
only
in
securities
of
innovation-driven
companies
may
affect
the
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
10,767,126
—
—
10,767,126
Investment
Companies
35,460
—
—
35,460
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
19
fund’s
exposure
to
certain
types
of
investments
and
may
adversely
impact
the
fund’s
performance
depending
on
whether
such
investments
are
in
or
out
of
favor
in
the
market.
Authorized
Participants,
Market
Makers
and
Liquidity
Providers
Risk:
The
fund
has
a
limited
number
of
financial
institutions
that
may
act
as
Authorized
Participants,
which
are
responsible
for
the
creation
and
redemption
activity
for
the
fund.
In
addition,
there
may
be
a
limited
number
of
market
makers
and/or
liquidity
providers
in
the
marketplace.
To
the
extent
either
of
the
following
events
occur,
fund
shares
may
trade
at
a
material
discount
to
net
asset
value
and
possibly
face
delisting:
(i)
Authorized
Participants
exit
the
business
or
otherwise
become
unable
to
process
creation
and/or
redemption
orders
and
no
other
Authorized
Participants
step
forward
to
perform
these
services,
or
(ii)
market
makers
and/or
liquidity
providers
exit
the
business
or
significantly
reduce
their
business
activities
and
no
other
entities
step
forward
to
perform
their
functions.
Non-Diversification
Risk:
Because
the fund
is
non-diversified,
its
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
(e)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions
are
recorded
on
the
ex-dividend
date.
Dividends
from
net
investment
income
and
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.
(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
and
net
realized
capital
gain
sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
As
of
and
during
the period
ended August
31,
2023,
the
fund
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 August
31,
2023,
the
fund
did
not
incur
any
interest
or
penalties.
The
tax
character
of
current
year
distributions
will
be
determined
at
the
end
of
the
current
fiscal
year.
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
20
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.50%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
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
August
31,
2023,
there
was
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-adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
Sub-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-advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-advisory
fee
paid
by
the
Adviser
to
a
Sub-Adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-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.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
rate
of
0.25%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser,
and
not
the
fund,
pays
the
Sub-Adviser
fee
rate.
21
(b)
The
fund
has
an
arrangement
with
The
Bank
of
New
York
Mellon
(the
“Custodian”),
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser, 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
ETF Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fee
of $4,526.
(c)
Each
Board
member
serves
as
a
Board
member
of
each
fund
within
the
Trust.
The
Board
members
are
not
compensated
directly
by
the
fund.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fee
paid
to
the
Adviser
by
the
fund.
The
quarterly
fees
are
paid
by
the
Adviser
from
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Trust,
including
the
fund.
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions,
during
the
period
ended
August
31,
2023, amounted
to $708,270
and
$419,903,
respectively.
At August
31,
2023,
accumulated
net
unrealized
appreciation on
investments
was
$803,165,
consisting
of
gross
appreciation
of
$1,365,870
and
gross
depreciation
of
$562,705.
At
August
31,
2023,
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
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
22
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.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
Seed
Capital:
As
of
August
31,
2023,
MBC
Investments
Corporation,
an
indirect
subsidiary
of
BNY
Mellon,
held
379,401
shares
of
the
fund.
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
August
31,
2023,
the
fund
had
in-kind
transactions
associated
with
creations
of
$9,670,888
and
redemptions
of
$0.
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT,
SUB-ADVISORY
AND
SUB-SUB
ADVISORY
AGREEMENTS
(Unaudited)
23
At
a
meeting
held
February
8,
2023
(the
“February
Meeting”),
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended
(the
“1940
Act”),
evaluated
proposals
to
approve
the
Management
Agreement
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
pursuant
to
which
the
Adviser
will
provide
the
BNY
Mellon
Innovators
ETF
(the
“fund”),
which
commenced
operations
during
the
period
covered
by
this
semi-annual
report,
with
investment
advisory
and
administrative
services,
and
the
Sub-Investment
Advisory
Agreement
(each
of
the
Management
Agreement
and
the
Sub-Investment
Advisory
Agreement,
an
“Agreement,”
and
collectively,
the
“Agreements”),
between
the
Adviser
and
Newton
Investment
Management
North
America,
LLC
(“NIMNA”
or
the
“Sub-
Adviser”),
an
affiliate
of
the
Adviser,
pursuant
to
which
the
Sub-Adviser
will
provide
day-to-day
management
of
the
fund’s
investments.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
The
Trustees
also
met
separately
from
management
to
consider
the
Agreements.
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,
Sub-Adviser
and/or
their
affiliates,
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’s
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
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
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT,
SUB-ADVISORY
AND
SUB-SUB
ADVISORY
AGREEMENTS
(Unaudited)
(continued)
24
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
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
mid-cap
growth
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.
The
Board
noted
The
Bank
of
New
York
Mellon
Corporation
may
derive
certain
benefits
from
an
incremental
growth
in
its
businesses
that
may
possibly
result
from
the
availability
of
the
fund
to
clients.
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.
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.
.
25
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.
**********
At
a
meeting
held
May
9,
2023
(the
“May
Meeting”),
the
Board
considered
the
approval
of
a
delegation
arrangement
between
NIMNA
and
its
affiliate,
Newton
Investment
Management
Limited
(“NIM”),
which
permits
NIMNA,
as
the
fund’s
Sub-Adviser,
to
use
the
investment
advisory
personnel,
resources
and
capabilities
(“Investment
Advisory
Services”)
available
at
its
sister
company,
NIM,
in
providing
the
day-to-day
management
of
the
fund’s
investments.
In
connection
therewith,
the
Board
considered
the
approval
of
a
sub-sub-investment
advisory
agreement
(the
“SSIA
Agreement”)
between
NIMNA
and
NIM,
with
respect
to
the
fund.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
The
Trustees
also
met
separately
from
management
to
consider
the
SSIA
Agreement.
At
the
May
Meeting,
the
Adviser
recommended
the
approval
of
the
SSIA
Agreement
to
enable
NIM
to
provide
Investment
Advisory
Services
to
the
Sub-Adviser
for
the
benefit
of
the
fund,
including,
but
not
limited
to,
portfolio
management
services,
subject
to
the
supervision
of
the
Sub-Adviser
and
the
Adviser.
The
recommendation
for
the
approval
of
the
SSIA
Agreement
was
based
on
the
following
considerations,
among
others:
(i)
approval
of
the
SSIA
Agreement
would
permit
the
Sub-Adviser
to
use
investment
personnel
employed
primarily
by
NIM
as
primary
portfolio
managers
of
the
fund
and
to
use
the
investment
research
services
of
NIM
in
the
day-to-day
management
of
the
fund’s
investments;
and
(ii)
there
would
be
no
material
changes
to
the
fund’s
investment
objective,
strategies
or
policies,
no
reduction
in
the
nature
or
level
of
services
provided
to
the
fund,
and
no
increases
in
the
management
fee
payable
by
the
fund
or
the
sub-advisory
fee
payable
by
the
Adviser
to
the
Sub-Adviser
as
a
result
of
the
delegation
arrangement.
The
Board
noted
NIM
currently
serves
as
the
sub-adviser
for
certain
other
series
of
the
Trust,
and
had
presented
to
the
Board
at
the
February
Meeting
with
respect
to
the
reapproval
of
the
NIM
sub-advisory
agreement
with
respect
to
those
series.
The
Board
further
noted
NIM
had
represented
there
had
been
no
material
changes
to
the
information
it
provided
at
the
February
Meeting.
In
approving
the
SSIA
Agreement,
the
Board
considered
the
materials
prepared
by
the
Adviser,
Sub-Adviser
and
NIM,
and
other
information
received
in
advance
of
the
May
Meeting,
which
included:
(i)
a
form
of
the
SSIA
Agreement
and
related
documents;
(ii)
information
regarding
the
delegation
arrangement
and
how
it
is
expected
to
enhance
investment
capabilities
for
the
benefit
of
the
fund;
(iii)
information
regarding
NIM;
and
(iv)
an
opinion
of
counsel
that
the
proposed
delegation
arrangement
would
not
result
in
an
“assignment”
of
the
Sub-Investment
Advisory
Agreement
under
the
1940
Act
and
the
Investment
Advisers
Act
of
1940,
as
amended,
and,
therefore,
did
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT,
SUB-ADVISORY
AND
SUB-SUB
ADVISORY
AGREEMENTS
(Unaudited)
(continued)
26
not
require
the
approval
of
fund
shareholders.
The
Board
also
considered
materials
provided
by
the
Adviser,
Sub-Adviser
and
NIM
received
in
advance
of
the
February
Meeting,
in
connection
with
(i)
the
Board’s
approval
of
the
Management
Agreement
and
Sub-Investment
Advisory
Agreement
with
respect
to
the
fund
and
(ii)
the
Board’s
re-approval
of
the
NIM
sub-investment
advisory
agreement
with
respect
to
the
other
series
of
the
Trust
for
which
NIM
serves
as
a
sub-adviser.
The
Board
also
took
into
consideration
the
substance
of
discussions
with
representatives
of
the
Adviser
and
Sub-Adviser
at
the
February
Meeting
and
May
Meeting.
For
More
Information
2023
BNY
Mellon
Securities
Corporation
4867SA0823
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
the
fund
daily.
The
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
“
SEC
”
)
for
the
first
and
third
quarters
of
the
fiscal
year
on
Form
N-PORT.
The
fund
’
s
Forms
N-PORT
are
available
on
the
SEC
’
s
website
at
www.sec.gov
.
Additionally,
the
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://im.bnymellon.com/etfliterature
.
The
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
the
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
the
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
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
Newton
Investment
Management
North
America,
LLC
BNY
Mellon
Center
201
Washington
Street
Boston,
MA
02108
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
Innovators
ETF
BKIV
BNY
Mellon
ETF
Trust
SEMI-ANNUAL
REPORT
August
31,
2023
BNY
Mellon
Women’s
Opportunities
ETF
Contents
The
Fund
Save
time.
Save
paper.
View
your
next
shareholder
report
online
as
soon
as
it’s
available.
Log
into
www.
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and
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up
for
eCommunications.
It’s
simple
and
only
takes
a
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
Discussion
of
Fund
Performance
3
Understanding
Your
Fund’s
Expenses
6
Statement
of
Investments
7
Statement
of
Assets
and
Liabilities
10
Statement
of
Operations
11
Statement
of
Changes
in
Net
Assets
12
Financial
Highlights
13
Notes
to
Financial
Statements
14
Information
About
the
Approval
of
the
Fund’s
Management,
Sub-Advisory
and
Sub-Sub
Advisory
Agreements
23
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
May
17,
2023,
the
fund’s
inception
1
,
through
August
31,
2023,
as
provided
by
Karen
Behr
and
Julianne
McHugh,
portfolio
managers
of
Newton
Investment
Management
North
America,
LLC
(NIMNA),
sub-adviser.
Market
and
Fund
Performance
Overview
For
the
period
from
May
17,
2023,
the
fund’s
inception,
through
August
31,
2023,
the
BNY
Mellon
Women’s
Opportunities
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
7.29%.
2
In
comparison,
the
fund’s
benchmark,
the
S&P
500
®
Index
(the
“Index”),
produced
a
total
return
of
10.23%
for
the
same
period.
3
Equities
gained
ground
during
the
reporting
period
as
inflationary
pressures
eased,
the
U.S.
Federal
Reserve
(the
“Fed”)
reduced
the
pace
of
interest-rate
hikes,
and
economic
growth
remained
positive.
The
fund
underperformed
the
Index
largely
due
to
relatively
weak
stock
selection.
The
Fund’s
Investment
Approach
The
fund
seeks
long-term
capital
growth.
To
pursue
its
goal,
the
fund
normally
invests
in
equity
securities
of
U.S.
companies
that
in
the
view
of
the
NIMNA,
an
affiliate
of
BNY
Mellon
ETF
Investment
Adviser,
LLC,
demonstrate
attractive
financial
attributes
and
promote
“Women’s
Opportunities.”
NIMNA
defines
“Women’s
Opportunities”
as
opportunities
that
enhance
the
professional
development
and
advancement
of
women
and/or
the
ability
of
women
to
meet
their
work
or
other
personal
life
responsibilities
and
needs.
NIMNA
considers
companies
that
promote
Women’s
Opportunities
to
be
companies
that
demonstrate
gender
equitable
practices
in
the
workplace
and/or
that
provide
products
or
services
that
NIMNA
believes
enhance
the
ability
of
women
to
meet
their
work
or
other
personal
life
responsibilities
and
needs.
NIMNA
utilizes
fundamental
research
and
analysis
to
select
investments
that
NIMNA
believes
possess
a
favorable
combination
of
qualitative
and
quantitative
metrics
relating
to
Women’s
Opportunities.
Equities
Advance
Despite
Macroeconomic
Concerns
Market
sentiment
proved
generally
positive
during
the
reporting
period,
with
hopes
for
continued
economic
growth
outweighing
concerns
regarding
persistently
high
levels
of
inflation
and
the
impact
of
central
bank
interest-rate
hikes
designed
to
curb
inflation.
In
May
2023,
as
the
period
began,
U.S.
inflation
averaged
4.05%
on
an
annualized
basis,
down
from
the
9.1%
peak
set
in
June
2022
but
above
the
target
of
2%
set
by
the
Fed.
The
benchmark
federal
funds
rate
stood
at
5.00%–5.25%,
the
highest
level
since
2007.
During
the
reporting
period,
inflation
fell
below
4%,
and
the
Fed
raised
rates
by
an
additional
0.25%,
with
few,
if
any,
additional
increases
expected
by
the
market.
Although
U.S.
economic
growth
and
corporate
profits
showed
signs
of
moderating,
indications
remained
broadly
positive,
supported
by
robust
consumer
spending,
rising
wages
and
low
levels
of
unemployment.
These
encouraging
economic
trends
eased
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
concerns
that
high
rates
might
tip
the
economy
into
a
recession.
Accordingly,
while
equity
markets
dipped
or
spiked
in
response
to
the
economic
news
of
the
day,
stocks
trended
higher
on
balance,
largely
driven
by
momentum
factors
among
large-cap
issues,
and
further
bolstered
by
the
improving
performance
of
value
factors.
Stock
Selections
Detract
from
Relative
Performance
Relative
to
the
Index,
the
fund’s
performance
was
impacted
by
stock
selection
in
communication
services
and
an
overweight
to
healthcare.
Within
Communication
Services,
Omnicom
Group,
Inc.
and
The
Walt
Disney
Company
detracted.
Omnicom
Group,
Inc.
shares
pulled
back
following
their
Q2
report
as
organic
growth
fell
short
of
expectations.
The
Walt
Disney
Company
underperformed
during
the
quarter
as
concerns
around
the
organization’s
Direct
to
Consumer
business—its
subscription
growth
and
profitability—weighed
on
shares.
The
fund’s
underweight
to
NVIDIA
Corp.
impacted
relative
performance
in
the
quarter
as
well.
While
we
maintained
a
positive
view
on
NVIDIA
Corp.’s
fundamental
positioning
and
its
practices
to
promote
a
gender
equitable
environment,
we
balanced
this
view
with
the
company’s
valuation
which
drove
initial
positioning
in
the
name.
Supporting
performance,
the
fund
saw
solid
performance
from
the
Industrials
sector.
Strong
stock
selection
drove
both
absolute
and
relative
outperformance.
Several
industrial
holdings
reported
better
than
expected
results
and
positive
outlooks
despite
slowing
US
economic
growth.
During
the
quarter,
the
fund’s
top
performers
overall
included
Uber
Technologies,
Inc.,
industrial
equipment
maker
Caterpillar,
Inc.,
and
software
firms
Intuit,
Inc.
and
Workday,
Inc.
Shares
in
Uber
Technologies,
Inc.
gained
as
improving
rideshare
volumes
supported
earnings
and
drove
a
positive
outlook.
The
company
continues
to
expand
their
global
offerings
addressing
customer
needs
with
their
offerings.
Caterpillar,
Inc.
shares
rose
as
the
company
exceeded
earnings
expectations
and
raised
guidance
on
strong
pricing
and
margins.
Intuit,
Inc.
and
Workday,
Inc.
both
benefited
from
resilient
demand
for
their
mission
critical
software
products.
The
fund’s
underweight
to
utilities
also
aided
relative
returns
in
the
quarter,
as
did
strong
stock
selection
in
the
sector.
Maintaining
a
Cautiously
Optimistic
Outlook
While
headline
inflation
is
falling
from
peak
levels,
as
of
August
31,
2023,
core
inflation
remains
stickier
than
investors
had
anticipated
in
many
markets.
With
the
Fed
currently
seen
as
poised
to
keep
interest
rates
elevated
for
longer
than
previously
expected,
the
real
economy
remains
vulnerable
as
the
impacts
of
past
rate
increases
work
their
way
through
the
system.
Accordingly,
we
remain
watchful
of
the
timing
and
extent
of
any
economic
weakness.
However,
structural
demand
trends
remain
in
place
as
many
global
transitions
continue
apace,
supported
in
some
cases
by
government
stimulus
and
support.
Against
this
backdrop,
we
will
continue
to
seek
out
those
businesses
with
attractive
sustainability
credentials,
durable
returns
and
quality
characteristics.
5
As
a
function
of
our
focus
on
investing
in
companies
that
deliver
products
and
services
that
enhance
women’s
opportunities
and
productivity,
the
fund
currently
holds
materially
overweight
exposure
to
the
health
care
sector.
We
believe
health
care
companies
that
offer
elder
care
services
should
benefit
from
increased
demand
as
a
result
of
a
growing
market
opportunity
given
the
country’s
aging
demographics
and
the
need
for
family
members
to
find
means
to
meet
dependent
care
responsibilities
while
balancing
paid
employment
responsibilities.
In
addition,
pharmaceutical
and
medical
device
companies
that
focus
on
women’s
health
issues
offer
critical
services
that
might
promote
women’s
productivity
by
reducing
sick
time.
Conversely,
the
fund
holds
underweight
exposure
to
communication
services,
partly
as
a
result
of
avoiding
Alphabet,
Inc.,
a
large
Index
position
that
we
do
not
believe
demonstrates
a
strong
gender
equality
environment.
The
company
has
faced
several
lawsuits
and
complaints
concerning
gender
pay
gap
discrimination
allegations,
has
relatively
weak
female
participation
trends
within
management,
and
lacks
evidence
of
strong
benefits.
We
believe
companies
that
work
to
level
the
playing
field
and
provide
women’s
opportunities
can
generate
more
resilient
returns,
regardless
of
the
economic
environment.
At
an
individual
company
level,
studies
show
that
companies
that
have
gender
diversity
in
senior
leadership
outperform
those
lacking
such
diversity
with
regards
to
profits,
return
on
asset
and
stock
performance.
Additional
studies
show
the
importance
of
strong
human
capital
metrics
on
financial
returns—those
companies
with
higher
employee
satisfaction
ratings
have
higher
returns.
Similarly,
companies
with
relatively
small
disparities
between
how
men
and
women
view
corporate
practices
outperform
those
with
wider
disparities.
We
further
believe
those
companies
offering
products
and
services
that
allow
women
to
better
balance
unpaid
and
paid
responsibilities
will
benefit
from
more
resilient
demand
and
offer
attractive
investment
opportunities.
September
15,
2023
1
The
inception
date
is
the
first
date
the
fund
was
available
on
The
NASDAQ
Stock
Market
LLC.
2
Total
return
includes
reinvestment
of
dividends
and
any
capital
gains
paid.
A
fund’s
net
asset
value
(NAV)
is
the
sum
of
all
its
assets
less
any
liabilities,
divided
by
the
number
of
shares
outstanding.
ETFs
are
bought
and
sold
at
market
prices,
not
NAV,
therefore
an
investor’s
return
at
market
price
may
differ
from
NAV.
Past
performance
is
no
guarantee
of
future
results.
Share
price,
yield
and
investment
return
fluctuate
such
that
upon
redemption,
fund
shares
may
be
worth
more
or
less
than
their
original
cost.
3
Source:
Lipper
Inc.
—
The
S&P
500
®
Index
is
widely
regarded
as
the
best
single
gauge
of
large-cap
U.S.
equities.
The
index
includes
500
leading
companies
and
captures
approximately
80%
coverage
of
available
market
capitalization.
Investors
cannot
invest
directly
in
any
index.
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.
Equities
are
subject
generally
to
market,
market
sector,
market
liquidity,
issuer
and
investment
style
risks,
among
other
factors,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
The
fund
is
non-diversified,
which
means
that
the
fund
may
invest
a
relatively
high
percentage
of
its
assets
in
a
limited
number
of
issuers.
Therefore,
the
fund’s
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
6
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
assuming
a
hypothetical
5%
annualized
return,
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.
For
the
six
months
ended
August
31,
2023
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
period
May
18,
2023
(commencement
of
operations)
to
August
31,
2023.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
106/366
(to
reflect
the
actual
days
in
the
period).
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
184/366
(to
reflect
the
one-half
period).
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)
1,000.00
1,000.00
1,072.90
1,022.62
1.50
2.54
0.50
STATEMENT
OF
INVESTMENTS
August
31,
2023
(Unaudited)
7
Description
Shares
Value
($)
Common
Stocks
–
98.8%
Banks
–
4.3%
Bank
of
America
Corp.
3,648
104,588
JPMorgan
Chase
&
Co.
2,416
353,533
458,121
Capital
Goods
–
3.2%
Caterpillar,
Inc.
616
173,176
Trane
Technologies
PLC
848
174,061
347,237
Consumer
Discretionary
Distribution
&
Retail
–
6.3%
Amazon.com,
Inc.
(a)
4,280
590,683
Etsy,
Inc.
(a)
1,213
89,240
679,923
Consumer
Durables
&
Apparel
–
1.9%
Lululemon
Athletica,
Inc.
(a)
536
204,355
Consumer
Services
–
2.5%
Bright
Horizons
Family
Solutions,
Inc.
(a)
2,826
266,831
Energy
–
4.6%
ConocoPhillips
1,012
120,458
Occidental
Petroleum
Corp.
2,773
174,117
Schlumberger
NV
3,384
199,521
494,096
Financial
Services
–
4.0%
Block,
Inc.
(a)
1,784
102,847
Mastercard,
Inc.,
Class
A
784
323,510
426,357
Food,
Beverage
&
Tobacco
–
2.1%
PepsiCo,
Inc.
1,288
229,161
Health
Care
Equipment
&
Services
–
9.4%
Addus
Homecare
Corp.
(a)
1,152
101,030
Boston
Scientific
Corp.
(a)
4,176
225,253
Centene
Corp.
(a)
1,604
98,887
Cooper
Cos.,
Inc.
(The)
643
237,904
Hologic,
Inc.
(a)
1,816
135,728
Progyny,
Inc.
(a)
5,520
206,117
1,004,919
Household
&
Personal
Products
–
2.0%
Estee
Lauder
Cos.,
Inc.
(The),
Class
A
1,328
213,184
Insurance
–
2.4%
Progressive
Corp.
(The)
1,888
251,991
STATEMENT
OF
INVESTMENTS
(continued)
8
Description
Shares
Value
($)
Common
Stocks
–
98.8%
(continued)
Materials
–
1.9%
Alcoa
Corp.
3,318
99,806
Constellium
SE
(a)
5,856
105,408
205,214
Media
&
Entertainment
–
4.0%
Meta
Platforms,
Inc.,
Class
A
(a)
633
187,298
Omnicom
Group,
Inc.
1,714
138,851
Walt
Disney
Co.
(The)
(a)
1,248
104,433
430,582
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
12.5%
AbbVie,
Inc.
2,248
330,366
Alnylam
Pharmaceuticals,
Inc.
(a)
480
94,954
Danaher
Corp.
992
262,880
Eli
Lilly
&
Co.
630
349,146
Illumina,
Inc.
(a)
1,352
223,377
Zoetis,
Inc.
423
80,586
1,341,309
Real
Estate
Management
&
Development
–
1.4%
CoStar
Group,
Inc.
(a)
1,779
145,860
Semiconductors
&
Semiconductor
Equipment
–
6.4%
Applied
Materials,
Inc.
1,335
203,935
NVIDIA
Corp.
720
355,356
Texas
Instruments,
Inc.
756
127,053
686,344
Software
&
Services
–
22.7%
Accenture
PLC,
Class
A
761
246,389
Akamai
Technologies,
Inc.
(a)
1,517
159,422
ANSYS,
Inc.
(a)
588
187,496
HubSpot,
Inc.
(a)
470
256,864
Intuit,
Inc.
592
320,751
Microsoft
Corp.
2,424
794,490
Shopify,
Inc.,
Class
A
(a)
4,488
298,407
Workday,
Inc.,
Class
A
(a)
720
176,040
2,439,859
Transportation
–
5.4%
FedEx
Corp.
1,104
288,166
Uber
Technologies,
Inc.
(a)
6,040
285,269
573,435
Utilities
–
1.8%
Exelon
Corp.
4,896
196,428
Total
Common
Stocks
(cost
$9,867,449)
10,595,206
9
See
Notes
to
Financial
Statements
Description
Shares
Value
($)
Investment
Companies
–
1.2%
Registered
Investment
Companies
–
1.2%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.30%
(b)(c)
(cost
$128,320)
128,320
128,320
Total
Investments
(cost
$9,995,769)
100.0%
10,723,526
Cash
and
Receivables
(Net)
0.0%
5,153
Net
Assets
100.0%
10,728,679
(a)
Non-income
producing
security.
(b)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(c)
The
rate
shown
is
the
1-day
yield
as
of
August
31,
2023.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
August
31,
2023
are
as
follows:
Description
Value
5/18/23
1
Purchases
($)
2
Sales
($)
Value
8/31/23
Dividends/
Distributions
($)
Investment
Companies
–
1.2%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
523,507
(395,187)
128,320
2,621
Total
–
1.2%
—
523,507
(395,187)
128,320
2,621
1
Commencement
of
operations.
2
Includes
reinvested
dividends/distributions.
Portfolio
Summary
(Unaudited)
†
Value
(%)
Information
Technology
29.1
Health
Care
21.9
Consumer
Discretionary
10.7
Financials
10.7
Industrials
8.6
Energy
4.6
Consumer
Staples
4.1
Communication
Services
4.0
Materials
1.9
Utilities
1.8
Real
Estate
1.4
Registered
Investment
Companies
1.2
100.0
†
Based
on
net
assets.
STATEMENT
OF
ASSETS
AND
LIABILITIES
August
31,
2023
(Unaudited)
10
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
–
Unaffiliated
issuers
9,867,449
10,595,206
Affiliated
issuers
128,320
128,320
Dividends
receivable
9,459
Tax
reclaim
receivable—Note
2(b)
159
10,733,144
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
4,465
4,465
Net
Assets
($)
10,728,679
Composition
of
Net
Assets
($):
Paid-in
capital
10,000,025
Total
distributable
earnings
(loss)
728,654
Net
Assets
($)
10,728,679
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
400,001
Net
asset
value
per
share
26.82
Market
price
per
share
26.84
STATEMENT
OF
OPERATIONS
For
the
Period
from
May
18,
2023
(commencement
of
operations)
to
August
31,
2023
(Unaudited)
11
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends
(net
of
$159
foreign
taxes
withheld
at
source):
Unaffiliated
issuers
30,857
Affiliated
issuers
2,621
Total
Income
33,478
Expenses:
Management
fee—Note
3(a)
15,180
Total
Expenses
15,180
Net
Investment
Income
18,298
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
(17,401
)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
727,75
7
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
710,356
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
728,654
STATEMENT
OF
CHANGES
IN
NET
ASSETS
12
See
Notes
to
Financial
Statements
For
the
Period
from
May
18,
2023
(a)
to
August
31,
2023
(Unaudited)
Operations
($):
Net
investment
income
18,298
Net
realized
gain
(loss)
on
investments
(17,401
)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
727,75
7
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
728,654
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
10,000,025
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
10,000,025
Total
Increase
(Decrease)
in
Net
Assets
10,728,679
Net
Assets
($):
Beginning
of
Period
—
End
of
Period
10,728,679
Changes
in
Shares
Outstanding:
Shares
sold
400,001
Net
Increase
(Decrease)
in
Shares
Outstanding
400,001
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
13
The
following
table
describes
the
performance
for
the
fiscal
period
indicated
and
these
figures
have
been
derived
from
the
fund’s
financial
statements.
See
Notes
to
Financial
Statements
For
the
Period
from
May
18,
2023
(a)
to
August
31,
2023
(Unaudited)
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
25.00
Investment
Operations:
Net
investment
income
(b)
0.05
Net
realized
and
unrealized
gain
(loss)
on
investments
1.77
Total
from
Investment
Operations
1.82
Net
asset
value,
end
of
period
26.82
Market
price,
end
of
period
(c)
26.84
Net
Asset
Value
Total
Return
(%)
(d)
7.29
(e)
Market
Price
Total
Return
(%)
(d)
7.36
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.50
(f)
Ratio
of
net
investment
income
to
average
net
assets
0.60
(f)
Portfolio
Turnover
Rate
(g)
15.16
Net
Assets,
end
of
period
($
x
1,000)
10,729
(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)
The
net
asset
value
total
return
and
the
market
price
total
return
is
calculated
from
fund
inception.
The
inception
date
is
the
first
date
the
fund
was
available
on
The
NASDAQ
Stock
Market
LLC.
(f)
Annualized.
(g)
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.
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
14
NOTE
1—Organization:
BNY
Mellon
Women's
Opportunities
ETF (the “fund”) is a
separate
non-
diversified series
of
BNY
Mellon
ETF
Trust
(the
“Trust”),
which is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-ended
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
seventeen
series,
including
the
fund.
The
fund
had
no
operations
until
May
18,
2023
(commencement
of
operations),
other
than
matters
relating
to
its
organization
and
registration
under
the
Act.
The
commencement
of
operations
date
is
considered
to
be
the
date
that
the
fund
began
trading
in
the
secondary
market.
The
investment
objective
of
the
fund
is
to
seek
long-term
capital
growth.
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. Newton
Investment
Management
North
America,
LLC (the
“Sub-Adviser”
or
“NIMNA”),
an
indirect wholly-owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-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.
Effective
May
31,
2023,
the
Sub-Adviser
entered
into
a
sub-sub-investment
advisory
agreement
with
its
affiliate,
Newton
Investment
Management
Limited
(“NIM”),
to
enable
NIM
to
provide
certain
advisory
services
to
the
Sub-Adviser
for
the
benefit
of
the
fund,
including,
but
not
limited
to,
portfolio
management
services.
NIM
is
subject
to
the
supervision
of
the
Sub-Adviser
and
the
Adviser.
NIM
is
also
an
affiliate
of
the
Adviser.
NIM,
located
at
160
Queen
Victoria
Street,
London,
EC4V
4LA,
England,
was
formed
in
1978.
NIM
is
an
indirect
subsidiary
of
BNY
Mellon.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“fund’s
Shares.”
The
fund’s
Shares
are
listed
and
traded
on
The
NASDAQ
Stock
Market
LLC.
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
NASDAQ
Stock
Market
LLC,
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
15
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
is 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.).
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
16
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:
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
equity
securities,
including
ETFs
(but
not
including
investments
in
other
open-end
registered
investment
companies),
generally
are
valued
at
the
last
sales
price
on
the
day
of
valuation
on
the
securities
exchange
or
national
securities
market
on
which
such
securities
primarily
are
traded.
Securities
listed
on
the
National
Association
of
Securities
Dealers
Automated
Quotation
System
(“NASDAQ”)
for
which
market
quotations
are
available
will
be
valued
at
the
official
closing
price.
If
there
are
no
transactions
in
a
security,
or
no
official
closing
prices
for
a
NASDAQ
market-listed
security
on
that
day,
the
security
will
be
valued
at
the
average
of
the
most
recent
bid
and
asked
prices.
Bid
price
is
used
when
no
asked
price
is
available.
Open
short
positions
for
which
there
is
no
sale
price
on
a
given
day
are
valued
at
the
lowest
asked
price.
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value.
All
of
the
preceding
securities
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
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 August
31,
2023
in
valuing
the
fund’s
investments:
17
Fair
Value
Measurements
(b)
Foreign
taxes:
The
fund
may
be
subject
to
foreign
taxes
(a
portion
of
which
may
be
reclaimable)
on
income,
stock
dividends,
realized
and
unrealized
capital
gains
on
investments
or
certain
foreign
currency
transactions.
Foreign
taxes
are
recorded
in
accordance
with
the
applicable
foreign
tax
regulations
and
rates
that
exist
in
the
foreign
jurisdictions
in
which
the
fund
invests.
These
foreign
taxes,
if
any,
are
paid
by
the
fund
and
are
reflected
in
the
Statement
of
Operations,
if
applicable.
Foreign
taxes
payable
or
deferred
or
those
subject
to
reclaims
as
of
August
31,
2023,
if
any,
are
disclosed
in
the
fund’s
Statement
of
Assets
and
Liabilities.
(c) 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.
(d)
Affiliated
issuers:
Investments
in
other
investment
companies
advised
by
the
Adviser
or
its
affiliates
are
defined
as
“affiliated”
under
the
Act.
(e)
Market
Risk:
The
value
of
the
securities
in
which
the
fund
invests
may
be
affected
by
political,
regulatory,
economic
and
social
developments,
and
developments
that
impact
specific
economic
sectors,
industries
or
segments
of
the
market.
The
value
of
a
security
may
also
decline
due
to
general
market
conditions
that
are
not
specifically
related
to
a
particular
company
or
industry,
such
as
real
or
perceived
adverse
economic
conditions,
changes
in
the
general
outlook
for
corporate
earnings,
changes
in
interest
or
currency
rates,
changes
to
inflation,
adverse
changes
to
credit
markets
or
adverse
investor
sentiment
generally.
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
the
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.
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
10,595,206
—
—
10,595,206
Investment
Companies
128,320
—
—
128,320
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
18
Investment
Theme Risk:
The
fund’s
incorporation
of
Women’s
Opportunities
considerations
into
its
investment
approach
may
cause
the
fund
to
make
different
investments
than
funds
that
invest
principally
in
equity
securities
but
do
not
incorporate
Women’s
Opportunities
considerations
when
selecting
investments.
Under
certain
economic
conditions,
this
could
cause
the
fund
to
underperform
funds
that
do
not
incorporate
Women’s
Opportunities
considerations.
For
example,
the
incorporation
of
Women’s
Opportunities
considerations
may
result
in
the
fund
forgoing
opportunities
to
buy
certain
securities
when
it
might
otherwise
be
advantageous
to
do
so
or
selling
securities
when
it
might
otherwise
be
disadvantageous
for
the
fund
to
do
so.
The
incorporation
of
Women’s
Opportunities
considerations
may
also
affect
the
fund’s
exposure
to
certain
sectors
and/or
types
of
investments
and
may
adversely
impact
the
fund’s
performance
depending
on
whether
such
sectors
or
investments
are
in
or
out
of
favor
in
the
market.
NIMNA’s
security
selection
process
incorporates
Women’s
Opportunities
data
provided
by
third
parties,
which
may
be
limited
for
certain
issuers
and/or
only
take
into
account
one
or
a
few
Women’s
Opportunities
related
components.
In
addition,
Women’s
Opportunities
data
may
include
quantitative
and/
or
qualitative
measures,
and
consideration
of
this
data
may
be
subjective.
Different
methodologies
may
be
used
by
the
various
data
sources
that
provide
Women’s
Opportunities
data.
Women’s
Opportunities
data
from
third
parties
used
by
NIMNA
as
part
of
its
process
often
lacks
standardization,
consistency
and
transparency,
and
for
certain
issuers
such
data
may
not
be
available
complete
or
accurate.
NIMNA’s
evaluation
of
Women’s
Opportunities
factors
relevant
to
a
particular
issuer
may
be
adversely
affected
in
such
instances.
As
a
result,
the
fund’s
investments
may
differ
from,
and
potentially
underperform,
funds
that
incorporate
Women’s
Opportunities
data
from
other
sources
or
utilize
other
methodologies.
Authorized
Participants,
Market
Makers
and
Liquidity
Providers Risk:
The
fund
has
a
limited
number
of
financial
institutions
that
may
act
as
Authorized
Participants,
which
are
responsible
for
the
creation
and
redemption
activity
for
the
fund.
In
addition,
there
may
be
a
limited
number
of
market
makers
and/or
liquidity
providers
in
the
marketplace.
To
the
extent
either
of
the
following
events
occur,
fund
shares
may
trade
at
a
material
discount
to
net
asset
value
and
possibly
face
delisting:
(i)
Authorized
Participants
exit
the
business
or
otherwise
become
unable
to
process
creation
and/or
redemption
orders
and
no
other
Authorized
Participants
step
forward
to
perform
these
services,
or
(ii)
market
makers
and/or
liquidity
providers
exit
the
business
or
significantly
reduce
their
business
activities
and
no
other
entities
step
forward
to
perform
their
functions.
Non-Diversification
Risk:
Because
the
fund
is
non-diversified,
its
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
19
(f)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions are
recorded
on
the
ex-dividend
date.
Dividends
from
net
investment
income
and
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.
(g)
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
and
net
realized
capital
gain sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
As
of
and
during
the period
ended August
31,
2023,
the
fund
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 August
31,
2023,
the
fund
did
not
incur
any
interest
or
penalties.
The
tax
character
of
current
year
distributions
will
be
determined
at
the
end
of
the
current
fiscal
year.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.50%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
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
August
31,
2023,
there
was
no
reduction
in
expenses
pursuant
to
the
undertaking.
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
20
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Sub-Adviser
serves
as
the
fund’s
sub-adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
Sub-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-advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-advisory
fee
paid
by
the
Adviser
to
a
Sub-Adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-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.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
rate
of
0.25%
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
Bank
of
New
York
Mellon
(the
“Custodian”),
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser, 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
ETF Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fee
of $4,465.
(c)
Each
Board
member
serves
as
a
Board
member
of
each
fund
within
the
Trust.
The
Board
members
are
not
compensated
directly
by
the
fund.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fee
paid
to
the
Adviser
by
the
fund.
The
quarterly
fees
are
paid
by
the
Adviser
from
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Trust,
including
the
fund.
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions,
during
the
period
ended
August
31,
2023, amounted
to $1,406,934
and
$1,259,296,
respectively.
21
At August
31,
2023,
accumulated
net
unrealized
appreciation on
investments
was
$727,757,
consisting
of
gross
appreciation
of
$956,655
and
gross
depreciation
of
$228,898.
At
August
31,
2023,
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.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
Seed
Capital:
As
of
August
31,
2023,
MBC
Investments
Corporation,
an
indirect
subsidiary
of
BNY
Mellon,
held
381,701
shares
of
the
fund.
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
22
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
August
31,
2023,
the
fund
had
in-kind
transactions
associated
with
creations
of
$9,737,212
and
redemptions
of
$0.
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT,
SUB-ADVISORY
AND
SUB-SUB
ADVISORY
AGREEMENTS
(Unaudited)
23
At
a
meeting
held
February
8,
2023
(the
“February
Meeting”),
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended
(the
“1940
Act”),
evaluated
proposals
to
approve
the
Management
Agreement
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
pursuant
to
which
the
Adviser
will
provide
the
BNY
Mellon
Women’s
Opportunities
ETF
(the
“fund”),
which
commenced
operations
during
the
period
covered
by
this
semi-annual
report,
with
investment
advisory
and
administrative
services,
and
the
Sub-Investment
Advisory
Agreement
(each
of
the
Management
Agreement
and
the
Sub-Investment
Advisory
Agreement,
an
“Agreement,”
and
collectively,
the
“Agreements”),
between
the
Adviser
and
Newton
Investment
Management
North
America,
LLC
(“NIMNA”
or
the
“Sub-Adviser”),
an
affiliate
of
the
Adviser,
pursuant
to
which
the
Sub-Adviser
will
provide
day-to-day
management
of
the
fund’s
investments.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
The
Trustees
also
met
separately
from
management
to
consider
the
Agreements.
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,
Sub-Adviser
and/or
their
affiliates,
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’s
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
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
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT,
SUB-ADVISORY
AND
SUB-SUB
ADVISORY
AGREEMENTS
(Unaudited)
(continued)
24
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
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
large
blend
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.
The
Board
noted
The
Bank
of
New
York
Mellon
Corporation
may
derive
certain
benefits
from
an
incremental
growth
in
its
businesses
that
may
possibly
result
from
the
availability
of
the
fund
to
clients.
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.
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.
25
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.
**********
At
a
meeting
held
May
9,
2023
(the
“May
Meeting”),
the
Board
considered
the
approval
of
a
delegation
arrangement
between
NIMNA
and
its
affiliate,
Newton
Investment
Management
Limited
(“NIM”),
which
permits
NIMNA,
as
the
fund’s
Sub-Adviser,
to
use
the
investment
advisory
personnel,
resources
and
capabilities
(“Investment
Advisory
Services”)
available
at
its
sister
company,
NIM,
in
providing
the
day-to-day
management
of
the
fund’s
investments.
In
connection
therewith,
the
Board
considered
the
approval
of
a
sub-sub-investment
advisory
agreement
(the
“SSIA
Agreement”)
between
NIMNA
and
NIM,
with
respect
to
the
fund.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
The
Trustees
also
met
separately
from
management
to
consider
the
SSIA
Agreement.
At
the
May
Meeting,
the
Adviser
recommended
the
approval
of
the
SSIA
Agreement
to
enable
NIM
to
provide
Investment
Advisory
Services
to
the
Sub-Adviser
for
the
benefit
of
the
fund,
including,
but
not
limited
to,
portfolio
management
services,
subject
to
the
supervision
of
the
Sub-Adviser
and
the
Adviser.
The
recommendation
for
the
approval
of
the
SSIA
Agreement
was
based
on
the
following
considerations,
among
others:
(i)
approval
of
the
SSIA
Agreement
would
permit
the
Sub-Adviser
to
use
investment
personnel
employed
primarily
by
NIM
as
primary
portfolio
managers
of
the
fund
and
to
use
the
investment
research
services
of
NIM
in
the
day-to-day
management
of
the
fund’s
investments;
and
(ii)
there
would
be
no
material
changes
to
the
fund’s
investment
objective,
strategies
or
policies,
no
reduction
in
the
nature
or
level
of
services
provided
to
the
fund,
and
no
increases
in
the
management
fee
payable
by
the
fund
or
the
sub-advisory
fee
payable
by
the
Adviser
to
the
Sub-Adviser
as
a
result
of
the
delegation
arrangement.
The
Board
noted
NIM
currently
serves
as
the
sub-adviser
for
certain
other
series
of
the
Trust,
and
had
presented
to
the
Board
at
the
February
Meeting
with
respect
to
the
reapproval
of
the
NIM
sub-advisory
agreement
with
respect
to
those
series.
The
Board
further
noted
NIM
had
represented
there
had
been
no
material
changes
to
the
information
it
provided
at
the
February
Meeting.
In
approving
the
SSIA
Agreement,
the
Board
considered
the
materials
prepared
by
the
Adviser,
Sub-Adviser
and
NIM,
and
other
information
received
in
advance
of
the
May
Meeting,
which
included:
(i)
a
form
of
the
SSIA
Agreement
and
related
documents;
(ii)
information
regarding
the
delegation
arrangement
and
how
it
is
expected
to
enhance
investment
capabilities
for
the
benefit
of
the
fund;
(iii)
information
regarding
NIM;
and
(iv)
an
opinion
of
counsel
that
the
proposed
delegation
arrangement
would
not
result
in
an
“assignment”
of
the
Sub-Investment
Advisory
Agreement
under
the
1940
Act
and
the
Investment
Advisers
Act
of
1940,
as
amended,
and,
therefore,
did
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
MANAGEMENT,
SUB-ADVISORY
AND
SUB-SUB
ADVISORY
AGREEMENTS
(Unaudited)
(continued)
26
not
require
the
approval
of
fund
shareholders.
The
Board
also
considered
materials
provided
by
the
Adviser,
Sub-Adviser
and
NIM
received
in
advance
of
the
February
Meeting,
in
connection
with
(i)
the
Board’s
approval
of
the
Management
Agreement
and
Sub-Investment
Advisory
Agreement
with
respect
to
the
fund
and
(ii)
the
Board’s
re-approval
of
the
NIM
sub-investment
advisory
agreement
with
respect
to
the
other
series
of
the
Trust
for
which
NIM
serves
as
a
sub-adviser.
The
Board
also
took
into
consideration
the
substance
of
discussions
with
representatives
of
the
Adviser
and
Sub-Adviser
at
the
February
Meeting
and
May
Meeting.
For
More
Information
2023
BNY
Mellon
Securities
Corporation
4868SA0823
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
the
fund
daily.
The
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
“
SEC
”
)
for
the
first
and
third
quarters
of
the
fiscal
year
on
Form
N-PORT.
The
fund
’
s
Forms
N-PORT
are
available
on
the
SEC
’
s
website
at
www.sec.gov
.
Additionally,
the
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://im.bnymellon.com/etfliterature
.
The
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
the
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
the
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
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
Newton
Investment
Management
North
America,
LLC
BNY
Mellon
Center
201
Washington
Street
Boston,
MA
02108
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
Women’s
Opportunities
ETF
BKWO
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)(1) Not applicable.
(a)(2)(2) Not applicable.
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 J. DiPetrillo, President
David J. DiPetrillo, President
(Principal Executive Officer)
Date 10/23/2023
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 J. DiPetrillo, President
David J. DiPetrillo, President
(Principal Executive Officer)
Date 10/23/2023
By (Signature and Title) * /s/ James Windels
James Windels, Treasurer
James Windels, Treasurer
(Principal Financial and Accounting Officer)
Date 10/20/2023
* Print the name and title of each signing officer under his or her signature.