UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number 811-23477
BNY Mellon ETF Trust
(Exact name of registrant as specified in charter)
240 Greenwich Street
_____________New York, New York 10286_____________
(Address of principal executive offices) (Zip code)
Deirdre Cunnane, Esq.
240 Greenwich Street
_________________New York, New York 10286_____________
(Name and address of agent for service)
Registrant's telephone number, including area code: (212) 922-6400
Date of fiscal year end: February 29
Date of reporting period: February 29, 2024
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 Equity 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, as amended (17 CFR 270.30e-1)(“1940 Act”).
BNY
Mellon
ETF
Trust
ANNUAL
REPORT
February
29,
2024
BNY
Mellon
Innovators
ETF
IMPORTANT
NOTICE
–
UPCOMING
CHANGES
TO
ANNUAL
AND
SEMI-ANNUAL
REPORTS
The
Securities
and
Exchange
Commission
(the
“SEC”)
has
adopted
rule
and
form
amendments
that
will
result
in
changes
to
the
design
and
delivery
of
annual
and
semi-annual
fund
reports
(“Reports”).
Beginning
in
July
2024,
Reports
will
be
streamlined
to
highlight
key
information.
Certain
information
currently
included
in
Reports,
including
financial
statements,
will
no
longer
appear
in
the
Reports
but
will
be
available
online,
delivered
free
of
charge
to
shareholders
upon
request,
and
filed
with
the
SEC.
If
you
previously
elected
to
receive
the
fund’s
Reports
electronically,
you
will
continue
to
do
so.
Otherwise,
you
will
receive
paper
copies
of
the
fund’s
re-designed
Reports
by
USPS
mail
in
the
future.
If
you
would
like
to
receive
the
fund’s
Reports
(and/or
other
communications)
electronically
instead
of
by
mail,
please
contact
your
financial
advisor.
Contents
The
Fund
Save
time.
Save
paper.
View
your
next
shareholder
report
online
as
soon
as
it’s
available.
Log
into
www.
im.bnymellon.com
and
sign
up
for
eCommunications.
It’s
simple
and
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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
Fund
Performance
7
Understanding
Your
Fund’s
Expenses
8
Statement
of
Investments
9
Statement
of
Assets
and
Liabilities
12
Statement
of
Operations
13
Statement
of
Changes
in
Net
Assets
14
Financial
Highlights
15
Notes
to
Financial
Statements
16
Report
of
Independent
Registered
Public
Accounting
Firm
25
Important
Tax
Information
26
Liquidity
Risk
Management
Program
27
Board
Members
Information
29
Officers
of
the
Trust
31
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
May
17,
2023,
the
fund’s
inception
1
,
through
February
29,
2024,
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
February
29,
2024,
the
BNY
Mellon
Innovators
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
24.11%.
2
In
comparison,
the
fund’s
benchmark,
the
Russell
3000
®
Growth
Index
(the
“Index”),
produced
a
total
return
of
33.05%
for
the
same
period.
3
Equities
gained
ground
during
the
reporting
period
as
inflationary
pressures
eased,
the
U.S.
Federal
Reserve
(the
“Fed”)
paused
its
program
of
interest-rate
hikes,
and
economic
growth
remained
positive.
The
fund
underperformed
the
Index
largely
due
to
overweight
exposure
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
BNY
Mellon
ETF
Investment
Adviser,
LLC
(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
Gain
Ground
Despite
Macroeconomic
Concerns
Market
sentiment
proved
strongly
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
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
the
Fed.
The
benchmark
federal
funds
rate
stood
at
5.00%–5.25%,
the
highest
level
since
2007.
During
the
period,
inflation
fell
to
near
3%,
and
the
Fed
raised
rates
by
an
additional
0.25%,
with
few,
if
any,
additional
increases
expected
by
the
market.
In
fact,
in
December
2023,
the
Fed
signaled
an
increasing
likelihood
of
rate
cuts
in
2024.
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.
The
Index
reached
several
new
record
levels
in
January
and
February
2024,
ending
the
period
at
an
all-time
high.
Health
Care
Positioning
Detracts
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
health
care
holdings
were
in
the
equipment
and
supplies
space,
where
shares
in
hemodialysis
system
maker
Outset
Medical,
Inc.
declined
sharply
as
the
company
faced
a
challenging
product
environment,
and
shares
in
sleep
apnea
treatment
developer
Inspire
Medical
Systems,
Inc.
fell
after
the
company
provided
disappointing
guidance.
The
life
sciences
area
also
detracted
materially
from
relative
returns,
due
in
part
to
declines
in
shares
of
gene
sequencing
company
Illumina,
Inc.,
which
faced
increasing
competition
and
a
gap
in
revenue
related
to
new
product
introductions,
and
sequencing
solutions
provider
Pacific
Biosciences
of
California,
Inc.,
which
reported
disappointing
revenues
and
underwhelming
guidance.
Other
sectors
that
detracted
from
relative
return,
though
to
a
lesser
extent
than
health
care,
included
consumer
discretionary
and
materials,
largely
due
to
stock
selection.
In
consumer
discretionary,
exercise
equipment
company
Peloton
Interactive,
Inc.
lost
ground
due
to
disappointing
corporate
execution
and
changing
post-pandemic
exercise
habits,
while
luxury
fashion
retailer
Farfetch
experienced
negative
impacts
from
slowing
consumer
spending.
In
materials,
specialty
chemicals
producer
Albemarle
faced
pressure
from
weak
lithium
prices
and
slowing
sales
due
to
oversupply.
5
On
the
positive
side,
the
fund’s
relative
returns
benefited
from
relatively
strong
individual
stock
selections
in
several
sectors.
In
consumer
staples,
shares
in
energy
drink
maker
Celsius
Holdings,
Inc.
rose
on
the
company’s
accelerating
growth,
while
holdings
in
pet
food
company
Freshpet,
Inc.
benefited
from
the
company’s
strong
volume
gains,
better-than-expected
profits
and
solid
outlook.
In
information
technology,
although
underweight
sector
exposure
detracted
from
relative
returns,
overweight
exposure
to
AI-related
semiconductor
maker
NVIDIA
Corp.
strongly
bolstered
performance.
In
finance,
shares
in
alternative
asset
manager
Ares
Management
Corp.
gained
ground
in
the
prevailing
environment
of
rising
interest
rates
and
tightening
banking
conditions,
while
commerce
and
payments
services
provider
Block,
Inc.
benefited
from
the
institutionalization
of
cryptocurrencies.
Maintaining
a
Cautiously
Optimistic
Outlook
While
the
U.S.
economy
has
performed
well
of
late
despite
high
interest
rates,
we
believe
wage
inflation
remains
a
cause
for
concern,
with
potential
to
spark
a
second
wave
of
inflation,
which—along
with
the
resilience
of
the
economy—may
prompt
the
Fed
to
delay
rate
cuts
longer
than
the
market
expects.
Nevertheless,
we
continue
to
find
attractive,
innovation-driven
investment
opportunities,
particularly
in
the
health
care
sector,
where
advances
in
genomics
and
AI
are
accelerating
drug
discovery
and
device
development.
Accordingly,
as
of
February
29,
2024,
the
fund
holds
significantly
overweight
exposure
to
health
care,
with
an
emphasis
on
biotechnology.
The
fund
also
holds
more
moderately
overweight
exposure
to
the
real
estate,
consumer
staples
and
energy
sectors.
Conversely,
as
of
the
same
date,
the
fund
holds
significantly
underweight
exposure
to
the
information
technology
sector,
where
innovation
remains
an
important
driver,
but
where
valuations
appear
higher
than
warranted
by
fundamentals.
The
fund
also
holds
underweight
exposure
to
the
consumer
discretionary
sector,
and
zero
exposure
to
industrials.
March
15,
2024
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
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
6
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
fund
may,
but
is
not
required
to,
use
derivative
instruments.
A
small
investment
in
derivatives
could
have
a
potentially
large
impact
on
the
fund's
performance.
The
use
of
derivatives
involves
risks
different
from,
or
possibly
greater
than,
the
risks
associated
with
investing
directly
in
the
underlying
assets.
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.
Please
note:
the
position
in
any
security
highlighted
with
italicized
typeface
was
sold
during
the
reporting
period.
FUND
PERFORMANCE
(Unaudited)
7
Comparison
of
change
in
value
of
a
$10,000
investment
in
BNY
Mellon
Innovators
ETF
with
a
hypothetical
investment
of
$10,000
in
the
Russell
3000
®
Growth
Index
(the
“Index”).
†
Source:
FactSet
††
The
inception
date
is
the
first
date
the
fund
was
available
on
The
NASDAQ
Stock
Market
LLC.
Past
performance
is
not
predictive
of
future
performance.
The
above
graph
compares
a
hypothetical
$10,000
investment
made
in
BNY
Mellon
Innovators
ETF
on
5/17/23
to
a
hypothetical
investment
of
$10,000
made
in
the
Index
on
that
date
using
closing
market
price
return.
All
dividends
and
capital
gain
distributions
are
reinvested.
The
fund’s
performance
shown
in
the
line
graph
above
takes
into
account
all
applicable
fees
and
expenses.
The
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.
An
investor
cannot
invest
directly
in
any
index.
Further
information
relating
to
fund
performance,
including
expense
reimbursements,
if
applicable,
is
contained
in
the
Financial
Highlight
section
of
the
prospectus
and
elsewhere
in
this
report.
The
performance
data
quoted
represents
past
performance,
which
is
no
guarantee
of
future
results.
Share
price
and
investment
return
fluctuate
and
an
investor’s
shares
may
be
worth
more
or
less
than
original
cost
upon
redemption.
Current
performance
may
be
lower
or
higher
than
the
performance
quoted.
Go
to
www.
im.bnymellon.com
for
the
fund’s
most
recent
month-end
returns.
The
fund’s
performance
shown
in
the
graph
and
table
does
not
reflect
the
deduction
of
taxes
that
a
shareholder
would
pay
on
fund
distributions
or
the
redemption
of
fund
shares.
Average
Annual
Total
Returns
as
of
February
29,
2024
Inception
Date
††
From
Inception
BNY
Mellon
Innovators
ETF
Net
Asset
Value
Return
5/17/23
24.11%
Market
Price
Return
5/17/23
23.92%
Russell
3000
®
Growth
Index
5/17/23
33.05%
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
8
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
table
below
shows
the
expenses
you
would
have
paid
on
a
$1,000
investment
in
the
fund
from
September
1,
2023
to
February
29,
2024.
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
February
29,
2024
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
period
ended
February
29,
2024.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
182/366
(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
1,148.90
1,022.38
2.67
2.51
0.50
STATEMENT
OF
INVESTMENTS
February
29,
2024
9
Description
Shares
Value
($)
Common
Stocks
–
98.4%
Consumer
Discretionary
Distribution
&
Retail
–
0.4%
Chewy,
Inc.,
Class
A
(a)
3,352
59,129
Consumer
Durables
&
Apparel
–
3.8%
Garmin
Ltd.
741
101,776
Lululemon
Athletica,
Inc.
(a)
618
288,662
Peloton
Interactive,
Inc.,
Class
A
(a)
31,932
144,333
534,771
Consumer
Services
–
3.3%
Airbnb,
Inc.,
Class
A
(a)
1,579
248,644
DraftKings,
Inc.,
Class
A
(a)
4,986
215,994
464,638
Energy
–
2.9%
Cactus,
Inc.,
Class
A
8,718
400,156
Financial
Services
–
5.3%
Ares
Management
Corp.,
Class
A
2,865
379,985
Block,
Inc.,
Class
A
(a)
4,531
360,078
740,063
Food,
Beverage
&
Tobacco
–
6.3%
Celsius
Holdings,
Inc.
(a)
4,199
342,722
Freshpet,
Inc.
(a)
3,557
402,048
Vital
Farms,
Inc.
(a)
7,677
137,956
882,726
Health
Care
Equipment
&
Services
–
13.4%
Align
Technology,
Inc.
(a)
978
295,767
DexCom,
Inc.
(a)
3,478
400,213
Inspire
Medical
Systems,
Inc.
(a)
1,376
246,359
Intuitive
Surgical,
Inc.
(a)
740
285,344
iRhythm
Technologies,
Inc.
(a)
1,549
183,789
Outset
Medical,
Inc.
(a)
8,504
26,788
Privia
Health
Group,
Inc.
(a)
6,722
150,035
PROCEPT
BioRobotics
Corp.
(a)(b)
1,103
53,319
TransMedics
Group,
Inc.
(a)
2,805
228,888
1,870,502
Media
&
Entertainment
–
12.0%
Alphabet,
Inc.,
Class
C
(a)
4,692
655,848
Liberty
Media
Corp.-Liberty
Formula
One,
Class
C
(a)
3,079
224,028
Netflix,
Inc.
(a)
838
505,247
Trade
Desk,
Inc.
(The),
Class
A
(a)
3,446
294,392
1,679,515
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
23.8%
10X
Genomics,
Inc.,
Class
A
(a)
3,254
151,767
Alnylam
Pharmaceuticals,
Inc.
(a)
1,180
178,286
Ascendis
Pharma
A/S,
ADR
(a)
2,517
371,912
BioMarin
Pharmaceutical,
Inc.
(a)
3,089
266,519
STATEMENT
OF
INVESTMENTS
(continued)
10
Description
Shares
Value
($)
Common
Stocks
–
98.4%
(continued)
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
23.8%
(continued)
Crinetics
Pharmaceuticals,
Inc.
(a)
2,873
117,621
Cytokinetics,
Inc.
(a)
1,580
114,139
Denali
Therapeutics,
Inc.
(a)
5,750
113,735
Illumina,
Inc.
(a)
1,732
242,186
Insmed,
Inc.
(a)
12,284
340,512
Keros
Therapeutics,
Inc.
(a)
2,467
166,523
Natera,
Inc.
(a)
2,075
179,467
Pacific
Biosciences
of
California,
Inc.
(a)(b)
22,182
122,666
Repligen
Corp.
(a)
1,489
288,851
Sarepta
Therapeutics,
Inc.
(a)
1,781
227,790
Twist
Bioscience
Corp.
(a)
8,782
345,045
Xenon
Pharmaceuticals,
Inc.
(a)
1,946
91,851
3,318,870
Real
Estate
Management
&
Development
–
4.0%
CoStar
Group,
Inc.
(a)
6,347
552,379
Semiconductors
&
Semiconductor
Equipment
–
10.7%
NVIDIA
Corp.
1,889
1,494,426
Software
&
Services
–
12.5%
DoubleVerify
Holdings,
Inc.
(a)
5,971
184,444
Dynatrace,
Inc.
(a)
4,844
240,020
MongoDB,
Inc.,
Class
A
(a)
605
270,786
Shopify,
Inc.,
Class
A
(a)
3,752
286,540
Snowflake,
Inc.,
Class
A
(a)
2,152
405,179
Twilio,
Inc.,
Class
A
(a)
5,935
353,667
1,740,636
Total
Common
Stocks
(cost
$11,139,748)
13,737,811
Investment
Companies
–
1.6%
Registered
Investment
Companies
–
1.6%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.28%
(c)(d)
(cost
$228,888)
228,888
228,888
Investment
of
Cash
Collateral
for
Securities
Loaned
–
1.3%
Registered
Investment
Companies
–
1.3%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.28%
(c)(d)
(cost
$180,158)
180,158
180,158
Total
Investments
(cost
$11,548,794)
101.3%
14,146,857
Liabilities,
Less
Cash
and
Receivables
(1.3)%
(183,985)
Net
Assets
100.0%
13,962,872
ADR—American
Depositary
Receipt
(a)
Non-income
producing
security.
11
See
Notes
to
Financial
Statements
(b)
Security,
or
portion
thereof,
on
loan.
At
February
29,
2024,
the
value
of
the
fund’s
securities
on
loan
was
$174,178
and
the
value
of
the
collateral
was
$180,158,
consisting
of
cash
collateral.
In
addition,
the
value
of
collateral
may
include
pending
sales
that
are
also
on
loan.
(c)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(d)
The
rate
shown
is
the
1-day
yield
as
of
February
29,
2024.
Portfolio
Summary
(Unaudited)
†
Value
(%)
Health
Care
37.2
Information
Technology
23.2
Communication
Services
12.0
Consumer
Discretionary
7.5
Consumer
Staples
6.3
Financials
5.3
Real
Estate
4.0
Registered
Investment
Companies
2.9
Energy
2.9
101.3
†
Based
on
net
assets.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
February
29,
2024
are
as
follows:
Description
Value
($)
5/18
/23
1
Purchases
($)
2
Sales
($)
Value
($)
2/29/24
Dividends/
Distributions
($)
Investment
Companies
–
1.6%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
978,889
(750,001)
228,888
4,940
Investment
of
Cash
Collateral
for
Securities
Loaned
–
1.3%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
554,757
(374,599)
180,158
41
3
Total
–
2.9%
—
1,533,646
(1,124,600)
409,046
4,981
1
Commencement
of
operations.
2
Includes
reinvested
dividends/distributions.
3
Represents
securities
lending
income
earned
from
the
reinvestment
of
cash
collateral
from
loaned
securities,
net
of
fees
and
collateral
investment
expenses,
and
other
payments
to
and
from
borrowers
of
securities.
STATEMENT
OF
ASSETS
AND
LIABILITIES
February
29,
2024
12
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments
(including
securities
on
loan,
valued
at
$174,178)—Note
2(b):
–
Unaffiliated
issuers
11,139,748
13,737,811
Affiliated
issuers
409,046
409,046
Dividends
receivable
1,564
Securities
lending
income
receivable
37
14,148,458
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
5,428
Liability
for
securities
on
loan—Note
2(b
)
180,158
185,586
Net
Assets
($)
13,962,872
Composition
of
Net
Assets
($):
Paid-in
capital
11,404,422
Total
distributable
earnings
(loss)
2,558,450
Net
Assets
($)
13,962,872
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
450,001
Net
asset
value
per
share
31.03
Market
price
per
share
30.98
STATEMENT
OF
OPERATIONS
For
the
Period
from
May
18,
2023
(commencement
of
operations)
to
February
29,
2024
13
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Unaffiliated
issuers
9,399
Affiliated
issuers
4,940
Income
from
securities
lending—Note
2(b
)
41
Total
Income
14,380
Expenses:
Management
fee—Note
3(a)
43,509
Total
Expenses
43,509
Net
Investment
(Loss)
(29,129)
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
(20,599)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
2,598,063
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
2,577,464
Net
Increase
from
Payment
by
Affiliate—Note
6
3,973
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
2,552,308
STATEMENT
OF
CHANGES
IN
NET
ASSETS
14
See
Notes
to
Financial
Statements
For
the
Period
from
May
18,
2023
(a)
to
February
29,
2024
Operations
($):
Net
investment
(loss)
(29,129)
Net
realized
gain
(loss)
on
investments
(20,599)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
2,598,063
Net
Increase
from
Payment
by
Affiliate—Note
6
3,973
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
2,552,308
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
11,410,535
Transaction
fees—Note
5
29
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
11,410,564
Total
Increase
(Decrease)
in
Net
Assets
13,962,872
Net
Assets
($):
Beginning
of
Period
—
End
of
Period
13,962,872
Changes
in
Shares
Outstanding:
Shares
sold
450,001
Net
Increase
(Decrease)
in
Shares
Outstanding
450,001
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
15
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
February
29,
2024
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
25.00
Investment
Operations:
Net
investment
(loss)
(b)
(0.07)
Net
realized
and
unrealized
gain
(loss)
on
investments
6.09
Payment
by
Affiliate
(c)
0.01
Total
from
Investment
Operations
6.03
Transaction
fees
(b)
0.00
(d)
Net
asset
value,
end
of
period
31.03
Market
price,
end
of
period
30.98
Net
Asset
Value
Total
Return
(%)
(e)
24.11
(f)
Market
Price
Total
Return
(%)
(e)
23.92
(f)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.50
(g)
Ratio
of
net
investment
(loss)
to
average
net
assets
(0.33)
(g)
Portfolio
Turnover
Rate
(h)
12.39
Net
Assets,
end
of
period
($
x
1,000)
13,963
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
The
total
return
for
the
fund
was
not
materially
impacted
by
the
reimbursement
to
the
fund
for
fund
losses
relating
to
trade
processing
error.
See
Note
6.
(d)
Amount
represents
less
than
$0.01
per
share.
(e)
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.
(f)
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.
(g)
Annualized.
(h)
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
16
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
thirteen
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
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
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
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).
17
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.).
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.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
18
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 February
29,
2024
in
valuing
the
fund’s
investments:
19
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.
Pursuant
to
a
securities
lending
agreement
with
BNY
Mellon,
the
fund
may
lend
securities
to
qualified
institutions.
It
is
the
fund’s
policy
that,
at
origination,
all
loans
are
secured
by
collateral
of
at
least
102%
of
the
value
of
U.S.
securities
loaned
and
105%
of
the
value
of
foreign
securities
loaned.
Collateral
equivalent
to
at
least
100%
of
the
market
value
of
securities
on
loan
is
maintained
at
all
times.
Collateral
is
either
in
the
form
of
cash,
which
can
be
invested
in
certain
money
market
mutual
funds
managed
by
the
Adviser,
or
U.S.
Government
and
Agency
securities.
Any
non-cash
collateral
received
cannot
be
sold
or
re-pledged
by
the
fund,
except
in
the
event
of
borrower
default.
The
securities
on
loan,
if
any,
are
also
disclosed
in
the
fund’s
Statement
of
Investments.
The
fund is
entitled
to
receive
all
dividends,
interest
and
distributions
on
securities
loaned,
in
addition
to
income
earned
as
a
result
of
the
lending
transaction.
Should
a
borrower
fail
to
return
the
securities
in
a
timely
manner,
BNY
Mellon
is
required
to
replace
the
securities
for
the
benefit
of
the
fund
or
credit
the
fund
with
the
market
value
of
the
unreturned
securities
and
is
subrogated
to
the
fund’s
rights
against
the
borrower
and
the
collateral.
Additionally,
the
contractual
maturity
of
security
lending
transactions
are
on
an
overnight
and
continuous
basis.
During
the
period
from
May
18,
2023
(commencement
of
operations)
to
February
29,
2024,
BNY
Mellon
earned
$6 from
the
lending
of
the
fund’s portfolio
securities,
pursuant
to
the
securities
lending
agreement.
For
financial
reporting
purposes,
the
fund
elects
not
to
offset
assets
and
liabilities
subject
to
a
securities
lending
agreement,
if
any,
in
the
Statement
of
Assets
and
Liabilities.
Therefore,
all
qualifying
transactions
are
presented
on
a
gross
basis
in
the
Statement
of
Assets
and
Liabilities.
As
of
February
29,
2024,
the
fund
had
securities
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
13,737,811
—
—
13,737,811
Investment
Companies
228,888
—
—
228,888
Investment
of
Cash
Collateral
for
Securities
Loaned
180,158
—
—
180,158
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
20
lending
and
the
impact
of
netting
of
assets
and
liabilities
and
the
offsetting
of
collateral
pledged
or
received,
if
any,
based
on
contractual
netting/set-off
provisions
in
the
securities
lending
agreement
are
detailed
in
the
following
table:
(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.
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
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
Assets
($)
Liabilities
($)
Securities
Lending
174,178
—
Total
gross
amount
of
assets
and
liabilities
in
the
Statement
of
Assets
and
Liabilities
174,178
—
Collateral
(received)/posted
not
offset
in
the
Statement
of
Assets
and
Liabilities
(174,178)
†
—
Net
Amount
—
—
†
The
value
of
the
related
collateral
received
by
the
fund
normally
exceeded
the
value
of
the
securities
loaded
by
the
fund
pursuant
to
the
securities
lending
agreement.
In
addition,
the
value
of
collateral
may
include
pending
sales
that
are
also
on
loan.
See
Statement
of
Investments
for
detailed
information
regarding
the
collateral
received
for
open
securities
lending.
21
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
continue
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 February
29,
2024,
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 February
29,
2024,
the
fund
did
not
incur
any
interest
or
penalties.
The
tax
year
in
the
period
ended February
29,
2024
remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities.
At February
29,
2024,
the
components
of
accumulated
earnings
on
a
tax
basis
were
as
follows:
accumulated
capital
losses
$20,599
and
unrealized appreciation
$2,587,208.
In
addition,
the
fund
had
$8,159
of
late
year
ordinary
losses
deferred
for
tax
purposes
to
the
first
day
of
the
following
fiscal
year.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
22
The
fund is
permitted
to
carry
forward
capital
losses
for
an
unlimited
period.
Furthermore,
capital
loss
carryovers
retain
their
character
as
either
short-term
or
long-
term
capital
losses.
The
accumulated
capital
loss
carryover
is
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
February
29,
2024.
The
fund
has
$20,599
of
short-term
capital
losses
which
can
be
carried
forward
for
an
unlimited
period.
The
fund
had
no
distributions
paid
to
shareholders
during
the
fiscal
year
ended
February
29,
2024.
During
the
period
ended
February
29,
2024,
as
a
result
of
permanent
book
to
tax
differences,
the
fund
increased
total
distributable
earnings
by
$10,115
and
decreased
paid-in
capital
by
the
same
amount.
These
permanent
book
to
tax
differences
are
primarily
due
to
the
tax
treatment
for
net
operating
losses.
Net
assets
and
net
asset
value
per
share
were
not
affected
by
these
reclassifications.
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
February
29,
2024,
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
23
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 $5,428.
(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
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
February
29,
2024, amounted
to $1,447,143
and
$1,367,460,
respectively.
At February
29,
2024,
the
cost
of
investments
for
federal
income
tax
purposes
was
$11,559,649;
accordingly,
accumulated
net
unrealized
appreciation on
investments
for
federal
income
tax
purposes
was
$2,587,208,
consisting
of
gross
appreciation
of
$3,360,413
and
gross
depreciation
of
$773,205.
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
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
24
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
February
29,
2024,
MBC
Investments
Corporation,
a
wholly-
owned
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
year
ended
February
29,
2024,
the
fund
had
in-kind
transactions
associated
with
creations
of
$11,085,519
and
redemptions
of
$0.
NOTE
6—Payment
from
Affiliate:
During
the
period
ended
February
29,
2024,
the
fund
was
reimbursed
$3,973
by
BNY
Mellon
for
fund
losses
relating
to a
trade
processing
error.
The
error
occurred
on
May
16,
2023
and
had
an
immaterial
impact
to
the
NAV
and
total
return
of
the
fund.
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
25
To
the
Shareholders
and
the
Board
of
Trustees
of
BNY
Mellon
Innovators
ETF
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
BNY
Mellon
Innovators
ETF
(the
“Fund”)
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust
(the
“Trust”)),
including
the
statement
of
investments,
as
of
February
29,
2024,
and
the
related
statements
of
operations,
changes
in
net
assets,
and
the
financial
highlights
for
the
period
from
May
18,
2023
(commencement
of
operations)
through
February
29,
2024
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Fund
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust)
at
February
29,
2024,
the
results
of
its
operations,
the
changes
in
its
net
assets
and
its
financial
highlights
for
the
period
from
May
18,
2023
(commencement
of
operations)
through
February
29,
2024,
in
conformity
with
U.S.
generally
accepted
accounting
principles.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Trust’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Fund’s
financial
statements
based
on
our
audit.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
("PCAOB")
and
are
required
to
be
independent
with
respect
to
the
Trust
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
conducted
our
audit
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audit
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Trust
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
the
Trust’s
internal
control
over
financial
reporting.
As
part
of
our
audit,
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Trust’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audit
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
February
29,
2024,
by
correspondence
with
the
custodian,
brokers
and
others;
when
replies
were
not
received
from
brokers
and
others,
we
performed
other
auditing
procedures.
Our
audit
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
We
believe
that
our
audit
provides
a
reasonable
basis
for
our
opinion.
We
have
served
as
the
auditor
of
one
or
more
investment
companies
in
the
BNY
Mellon
Family
of
Funds
since
at
least
1957,
but
we
are
unable
to
determine
the
specific
year.
New
York,
New
York
April
19,
2024
IMPORTANT
TAX
INFORMATION
(Unaudited)
26
Form
1099-DIV,
Form
1042-S
and
other
year–end
tax
information
provide
shareholders
with
actual
calendar
year
amounts
that
should
be
included
in
their
tax
returns.
Shareholders
should
consult
their
tax
advisers.
The
following
distribution
information
is
being
provided
as
required
by
the
Internal
Revenue
Code
or
to
meet
a
specific
state’s
requirement.
The
fund
designates
the
following
amounts
or,
if
subsequently
determined
to
be
different,
the
maximum
amount
allowable
for
its
fiscal
year
ended February
29,
2024:
For
federal
tax
purposes
the
fund
hereby
reports
0.00%
of
ordinary
income
dividends
paid
during
the
fiscal
year
ended
February
29,
2024 as
qualified
dividend
income.
LIQUIDITY
RISK
MANAGEMENT
PROGRAM
(Unaudited)
27
The
funds
of
the
Trust
have
adopted
a
liquidity
risk
management
program
(the
“Program”)
pursuant
to
the
requirements
of
Rule
22e-4
under
the
Investment
Company
Act
of
1940,
as
amended.
Rule
22e-4
requires
registered
open-end
funds,
including
exchange-traded
funds,
to
establish
liquidity
risk
management
programs
in
order
to
effectively
manage
fund
liquidity
and
shareholder
redemptions.
The
rule
is
designed
to
mitigate
the
risk
that
a
fund
could
not
meet
redemption
requests
without
significantly
diluting
the
interests
of
remaining
investors.
The
Board
has
appointed
BNY
Mellon
ETF
Investment
Adviser,
LLC,
the
investment
adviser
to
the
funds,
as
the
Program
Administrator.
The
rule
requires
each
fund
to
assess,
manage
and
review
its
liquidity
risk
at
least
annually,
considering
applicable
factors
such
as
investment
strategy
and
liquidity
during
normal
and
reasonably
foreseeable
stressed
conditions,
including
whether
the
strategy
is
appropriate
for
an
open-end
fund
and
whether
the
fund
has
a
relatively
concentrated
portfolio
or
large
positions
in
particular
issuers.
Each
fund
must
also
assess
its
use
of
borrowings
and
derivatives,
short-
term
and
long-term
cash
flow
projections
in
normal
and
reasonably
foreseeable
stressed
conditions,
holdings
of
cash
and
cash
equivalents,
and
borrowing
arrangements
and
other
funding
sources.
In
addition,
with
respect
to
an
exchange-traded
fund,
a
fund
must
assess
the
relationship
between
the
fund’s
portfolio
liquidity
and
the
way
in
which,
and
the
prices
and
spreads
at
which,
the
fund’s
shares
trade,
and
the
effect
of
the
composition
of
baskets
on
the
overall
liquidity
of
the
fund’s
portfolio.
The
rule
also
generally
requires
funds
to
classify
each
of
their
investments
as
highly
liquid,
moderately
liquid,
less
liquid
or
illiquid
based
on
the
number
of
days
the
fund
expects
it
would
take
to
liquidate
the
investment,
and
to
review
these
classifications
at
least
monthly
or
more
often
under
certain
conditions.
Illiquid
investments
are
those
a
fund
does
not
expect
to
be
able
to
sell
or
dispose
of
within
seven
calendar
days
without
the
sale
or
disposition
significantly
changing
the
market
value
of
the
investment.
A
fund
is
prohibited
from
acquiring
an
investment
if,
after
the
acquisition,
its
holdings
of
illiquid
assets
will
exceed
15%
of
its
net
assets.
In
addition,
if
a
fund
permits
redemptions
in-kind,
the
rule
requires
the
fund
to
establish
redemption
in-kind
policies
and
procedures
governing
how
and
when
it
will
engage
in
such
redemptions.
Pursuant
to
the
rule’s
requirements,
the
Program
has
been
reviewed
and
approved
by
the
Board.
Furthermore,
at
its
November
2023
meeting,
the
Board
received
a
written
report
prepared
by
the
Program
Administrator,
for
the
period
October
1,
2022
to
September
30,
2023,
addressing
the
operation
of
the
Program,
assessing
the
Program’s
adequacy
and
effectiveness
and
describing
any
material
changes
made
to
the
Program.
LIQUIDITY
RISK
MANAGEMENT
PROGRAM
(Unaudited)
(continued)
28
Assessment
of
Program
In
the
opinion
of
the
Program
Administrator,
the
Program
approved
by
the
Board
continues
to
be
adequate
for
the
funds
and
the
Program
has
been
implemented
effectively.
The
Program
Administrator
has
monitored
each
fund’s
liquidity
risk
and
the
liquidity
classification
of
the
securities
held
by
the
funds
and
has
determined
that
the
Program
is
operating
effectively.
During
the
period
from
October
31,
2022
to
September
30,
2023,
there
were
no
material
changes
to
the
Program
and
no
material
liquidity
events
that
impacted
the
funds.
During
the
period,
each
fund
held
sufficient
highly
liquid
assets
to
meet
fund
redemptions.
Under
normal
expected
foreseeable
fund
redemption
forecasts
and
foreseeable
stressed
fund
redemption
forecasts,
the
Program
Administrator
believes
that
each
fund
maintains
sufficient
highly
liquid
assets
to
meet
expected
fund
redemptions.
BOARD
MEMBERS
INFORMATION
(Unaudited)
INDEPENDENT
BOARD
MEMBERS
29
J.
Charles
Cardona
(68)
Chairman
of
the
Board
(2020)
Principal
Occupation
During
Past
5
Years:
BNY
Mellon
Family
of
Funds,
Interested
Director
(2014-2018),
Independent
Director
(2019-Present)
BNY
Mellon
Liquidity
Funds,
Director
(2004-Present)
and
Chairman
(2019-2021)
No.
of
Portfolios
for
which
Board
Member
Serves:
35,
including
19
managed
by
an
affiliate
of
the
Adviser
Kristen
M.
Dickey
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Independent
board
director
of
Marstone,
Inc.,
a
financial
technology
company
(since
2018);
Lead
non-executive
director
for
Aperture
Investors,
LLC,
an
investment
management
firm
(since
2018);
Managing
Director—Global
Head
of
Index
Strategy
at
BlackRock,
Inc.
(until
2017).
No.
of
Portfolios
for
which
Board
Member
Serves:
13
F.
Jack
Liebau,
Jr.
(60)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
Director
at
Beach
Investment
Counsel,
a
financial
advisory
firm
(since
2020)
Corporate
director
(since
2015)
Other
Public
Company
Board
Memberships
During
Past
5
Years:
Myers
Industries,
an
industrial
company,
Director
(2015
–
Present)
and
Chairman
of
Board
(2016
–
Present)
STRATTEC
Security
Corp.,
an
automotive
power
and
security
solutions
company,
Director
(2023
–
Present)
and
Chairman
of
Board
(2024
–
Present)
No.
of
Portfolios
for
which
Board
Member
Serves:
13
Jill
I.
Mavro
(51)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
director
at
Ecoban
Securities,
LLC,
a
financial
technology
consulting
company
(since
2020)
Founder
and
Principal
of
Spoondrift
Advisory,
LLC
(since
2018);
Senior
Managing
Director,
Head
of
Strategic
Relationships
and
Member
of
SPDR
Executive
Committee
at
State
Street
Global
Advisors
(until
2018)
No.
of
Portfolios
for
which
Board
Member
Serves:
13
30
BOARD
MEMBERS
INFORMATION
(Unaudited)
(continued)
INDEPENDENT
BOARD
MEMBERS
Kevin
W.
Quinn
(64)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Partner
at
PricewaterhouseCoopers,
LLC
(until
2019)
No.
of
Portfolios
for
which
Board
Member
Serves:
13
Stacy
L.
Schaus
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Chief
Executive
Officer
of
the
Schaus
Group
LLC,
a
consulting
firm
(since
2019);
Advisory
board
member
of
A&P
Capital,
a
consulting
firm
(from
2019-2021);
Executive
Vice
President—Defined
Contribution
Practice
Founder
at
PIMCO
Investment
Management
(until
2018).
No.
of
Portfolios
for
which
Board
Member
Serves:
13
The
address
of
the
Board
Members
and
Officers
is
c/o
BNY
Mellon
ETF
Investment
Adviser,
LLC,
240
Greenwich
Street,
New
York,
New
York
10286.
Additional
information
about
each
Board
Member
is
available
in
the
fund’s
Statement
of
Additional
Information
which
can
be
obtained
from
the
Adviser
free
of
charge
by
calling
this
toll
free
number:
1-833-383-2696.
OFFICERS
OF
THE
TRUST
(Unaudited)
31
DAVID
DIPETRILLO,
President
since
February
2020.
Vice
President
and
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2021;
Head
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
February
2023;
Head
of
North
America
Product,
BNY
Mellon
Investment
Management
from
January
2018
to
February
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
99
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
46
years
old
and
has
been
an
employee
of
BNY
Mellon
since
2005.
PETER
M.
SULLIVAN,
Chief
Legal
Officer
since
July
2021,
Vice
President
and
Assistant
Secretary
since
February
2020.
Chief
Legal
Officer
of
BNY
Mellon
Investment
Adviser,
Inc.
and
Associate
General
Counsel
of
BNY
Mellon
since
July
2021;
Senior
Managing
Counsel
of
BNY
Mellon
from
December
2020
to
July
2021;
and
Managing
Counsel
of
BNY
Mellon
from
March
2009
to
December
2020.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
since
April
2004.
JAMES
WINDELS,
Treasurer
since
February
2020.
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2023;
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
September
2020;
and
Director
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
65
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1985.
SARAH
S.
KELLEHER,
Vice
President
and
Secretary
since
February
2020.
Vice
President
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
since
February
2020;
Senior
Managing
Counsel
of
BNY
Mellon
since
September
2021;
and
Managing
Counsel
of
BNY
Mellon
from
December
2017
to
September
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
48
years
old
and
has
been
an
employee
of
BNY
Mellon
since
March
2013.
JAMES
BITETTO,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon
since
December
2019;
Managing
Counsel
of
BNY
Mellon
from
April
2014
to
December
2019;
and
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
57
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
December
1996.
DEIRDRE
CUNNANE,
Vice
President
and
Assistant
Secretary
since
February
2020.
Managing
Counsel
of
BNY
Mellon
since
December
2021;
and
Counsel
of
BNY
Mellon
from
August
2018
to
December
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
32
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
August
2018.
JEFF
PRUSNOFSKY,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
58
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
October
1990.
OFFICERS
OF
THE
TRUST
(Unaudited)
(continued)
32
AMANDA
QUINN,
Vice
President
and
Assistant
Secretary
since
February
2020.
Counsel
of
BNY
Mellon
since
June
2019;
and
Regulatory
Administration
Manager
at
BNY
Mellon
Investment
Management
Services from
September
2018
to
May
2019.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
June
2012.
JOANNE
SKERRETT,
Vice
President
and
Assistant
Secretary
since
March
2023.
Managing
Counsel
of
BNY
Mellon
since
June
2022;
and
Senior
Counsel
with
the
Mutual
Fund
Directors
Forum,
a
leading
funds
industry
organization,
from
2016
to
June
2022.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
51
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
2022.
DANIEL
GOLDSTEIN,
Vice
President
since
March
2022
Head
of
Product
Development
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023;
and
Senior
Vice
President,
Development
&
Oversight
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
99
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
the
Distributor
since
1991.
JOSEPH
MARTELLA,
Vice
President
since
March
2022
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
December
2022;
Head
of
Product
Management
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023,
and
Senior
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
99
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
47
years
old
and
has
been
an
employee
of
the
Distributor
since
1999.
GAVIN
C.
REILLY,
Assistant
Treasurer
since
February
2020.
Tax
Manager-BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1991.
ROBERT
SALVIOLO,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
1989.
ROBERT
SVAGNA,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
November
1990.
33
NATALYA
ZELENSKY,
Vice
President
and
Assistant
Secretary
since
February
2020
and
Chief
Compliance
Officer
since
August
2021.
Chief
Compliance
Officer
since
August
2021
and
Vice
President
since
February
2020
of
BNY
Mellon
ETF
Investment
Adviser,
LLC;
Managing
Counsel
of
BNY
Mellon
from
December
2019
to
August
2021;
Counsel
of
BNY
Mellon
from
May
2016
to
December
2019;
and
Assistant
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
from
April
2018
to
August
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
May
2016.
CARIDAD
M.
CAROSELLA,
Anti-Money
Laundering
Compliance
Officer
since
February
2020.
Anti-Money
Laundering
Compliance
Officer
of
the
BNY
Mellon
Family
of
Funds
and
BNY
Mellon
Funds
Trust.
She
is
an
officer
of
47
investment
companies
(comprised
of
110
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
55
years
old
and
has
been
an
employee
of
the
Distributor
since
1997.
For
More
Information
2024
BNY
Mellon
Securities
Corporation
4867AR0224
Telephone
Call
your
financial
representative
or
1-833-ETF-BNYM
(383-2696)
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and
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BNY
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Street
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York,
NY
10286
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Management
North
America,
LLC
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NY
10286
Ticker
Symbol:
BNY
Mellon
Innovators
ETF
BKIV
BNY
Mellon
ETF
Trust
ANNUAL
REPORT
February
29,
2024
BNY
Mellon
Women’s
Opportunities
ETF
IMPORTANT
NOTICE
–
UPCOMING
CHANGES
TO
ANNUAL
AND
SEMI-ANNUAL
REPORTS
The
Securities
and
Exchange
Commission
(the
“SEC”)
has
adopted
rule
and
form
amendments
that
will
result
in
changes
to
the
design
and
delivery
of
annual
and
semi-annual
fund
reports
(“Reports”).
Beginning
in
July
2024,
Reports
will
be
streamlined
to
highlight
key
information.
Certain
information
currently
included
in
Reports,
including
financial
statements,
will
no
longer
appear
in
the
Reports
but
will
be
available
online,
delivered
free
of
charge
to
shareholders
upon
request,
and
filed
with
the
SEC.
If
you
previously
elected
to
receive
the
fund’s
Reports
electronically,
you
will
continue
to
do
so.
Otherwise,
you
will
receive
paper
copies
of
the
fund’s
re-designed
Reports
by
USPS
mail
in
the
future.
If
you
would
like
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receive
the
fund’s
Reports
(and/or
other
communications)
electronically
instead
of
by
mail,
please
contact
your
financial
advisor.
Contents
The
Fund
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time.
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paper.
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next
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The
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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
Fund
Performance
7
Understanding
Your
Fund’s
Expenses
8
Statement
of
Investments
9
Statement
of
Assets
and
Liabilities
12
Statement
of
Operations
13
Statement
of
Changes
in
Net
Assets
14
Financial
Highlights
15
Notes
to
Financial
Statements
16
Report
of
Independent
Registered
Public
Accounting
Firm
25
Important
Tax
Information
26
Liquidity
Risk
Management
Program
27
Board
Members
Information
29
Officers
of
the
Trust
31
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
May
17,
2023,
the
fund’s
inception
1
,
through
February
29,
2024,
as
provided
by
Karen
Behr
and
Julianne
McHugh,
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
February
29,
2024,
the
BNY
Mellon
Women’s
Opportunities
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
26.36%.
2
In
comparison,
the
fund’s
benchmark,
the
S&P
500
®
Index
(the
“Index”),
produced
a
total
return
of
24.78%
for
the
same
period.
3
Equities
gained
ground
during
the
reporting
period
as
inflationary
pressures
eased,
the
U.S.
Federal
Reserve
(the
“Fed”)
paused
its
program
of
interest-rate
hikes,
and
economic
growth
remained
positive.
The
fund
outperformed
the
Index
largely
due
to
relatively
strong
stock
selection
in
the
industrials
and
consumer
discretionary
sectors.
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
Newton
Investment
Management
North
America
LLC
(“NIMNA”),
an
affiliate
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
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
strongly
positive
during
the
reporting
period.
Hopes
for
continued
economic
growth
outweighed
concerns
regarding
persistently
high
levels
of
inflation
and
the
need
for
central
bank
interest-rate
hikes
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
2%
set
by
the
Fed.
The
benchmark
federal
funds
rate
stood
at
5.00%-5.25%,
the
highest
level
since
2007.
During
the
period,
inflation
fell
to
near
3%,
and
the
Fed
raised
rates
by
an
additional
0.25%
with
few,
if
any
additional
increases
expected
by
the
market.
In
fact,
in
December
2023,
the
Fed
signaled
an
increasing
likelihood
of
rate
cuts
in
2024.
Although
U.S.
economic
growth
and
corporate
profits
showed
signs
of
moderating,
indications
remained
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
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.
The
Index
reached
new
record
levels
in
late
January
and
February
2024,
ending
the
period
at
an
all-time
high.
Stock
Selection
Bolsters
Relative
Performance
Relative
to
the
Index,
the
fund’s
performance
was
enhanced
by
stock
selection
in
the
industrials
and
consumer
discretionary
sectors.
Within
industrials,
Uber
Technologies,
Inc.,
Trane
Technologies
PLC
and
Caterpillar,
Inc.
drove
relative
returns.
Uber
Technologies,
Inc.,
a
ridesharing
and
delivery
company,
reported
a
solid
quarter
as
driver
costs
continued
to
normalize
and
end
markets
recovered.
The
company
also
continued
to
build
out
complementary
businesses
highlighting
developments
in
delivery
and
advertising
which
supported
recent
performance
and
contributes
to
their
long
term
outlook.
Trane
Technologies
PLC,
a
heating,
ventilation
and
air
conditioning
(HVAC)
company,
benefited
from
continued
corporate
investment
in
industrial
HVAC
system
installations.
Given
the
energy
reduction
associated
with
updating
older
systems,
companies
continued
to
spend
on
these
products.
Increasing
infrastructure
spend
provided
a
further
tailwind
for
Trane
Technologies
PLC
and
supported
Caterpillar,
Inc.,
a
construction
equipment
maker,
as
well.
In
consumer
discretionary,
top
positive
contributors
included
online
retailer
Amazon.com,
Inc.
and
childcare
and
education
services
provider
Bright
Horizons
Family
Solutions,
Inc.
Amazon.com,
Inc.
delivered
solid
performance,
capitalizing
on
earlier
investments
in
its
distribution
network
and
growing
business
demand
for
Amazon
Web
Services.
Bright
Horizons
Family
Solutions,
Inc.
benefited
from
increased
enrollment
at
their
centers
coupled
with
a
positive
outlook
for
utilization
rates
at
backup-care
centers
as
parents
reap
the
benefits
of
opportunities
to
stay
fully
engaged
within
the
workforce.
Other
notably
strong
contributors
to
performance
included
pharmaceutical
company
Eli
Lilly
&
Co.,
which
saw
strong
demand
for
their
new
obesity
drugs,
and
financial
software
developer
Intuit,
Inc.
Performance
relative
to
the
Index
further
benefited
from
the
fund’s
lack
of
exposure
to
consumer
electronics
maker
Apple
and
electronic
vehicle
company
Tesla,
both
of
which
lagged
during
the
period.
From
an
industry
perspective,
top
performing
industries
included
technology,
hardware,
storage
and
peripherals,
ground
transportation,
and
pharmaceuticals.
With
respect
to
detractors,
investments
in
consumer
staples
and
healthcare
weighed
on
the
fund’s
relative
returns.
Notable
detractors
included
cosmetics
and
personal
care
products
maker
The
Estée
Lauder
Companies
(“Estée
Lauder”)
.
Estée
Lauder
encountered
headwinds
this
past
year
related
to
softness
in
the
company’s
key
Chinese
market.
Concerns
regarding
the
duration
of
this
Chinese
consumer
slowdown
prompted
the
fund
to
sell
its
position.
Illumina,
Inc.
shares
were
hurt
by
sector-wide
biotechnology
5
funding
softness,
a
marked
reduction
in
Chinese
health
care
capital
expenditure
spending,
as
well
as
disruption
associated
with
a
new
product
launch;
however,
we
view
these
issues
as
transient
and
remain
constructive
around
the
firm’s
long
term
outlook.
Returns
were
impacted
by
the
fund’s
underweight
to
semiconductor
maker
NVIDIA
Corp.
early
in
the
reporting
period,
although
notably
the
underweight
was
closed.
Industries
that
materially
detracted
from
relative
returns
included
semiconductors,
personal
care
products
and
life
science
tools.
Focusing
on
Companies
Positioned
to
Navigate
the
Changing
Landscape
Thus
far,
tighter
monetary
policy
and
financial
conditions
appear
to
have
been
absorbed
by
investors
without
significant
disruption
to
global
financial
markets.
Economic
conditions
also
appear
to
have
been
more
resilient
than
anticipated,
and
soft-landing
conditions
appear
in
prospect.
However,
inflation
continues
to
be
stickier
than
hoped
for,
which
is
acting
as
a
brake
on
the
ability
of
central
banks
to
cut
interest
rates.
A
higher-for-longer
rates
scenario
may
yet
give
investors
pause
for
thought.
Geopolitics,
ongoing
conflicts,
trade
wars
and
China’s
recovery
from
economic
malaise
all
have
the
potential
to
have
a
disruptive
influence
on
economies
and
markets
over
the
short
term.
Nonetheless,
we
continue
to
see
attractive
long-term
investment
opportunities
given
the
structural
demand
trends
that
remain
in
place.
Following
a
period
during
which
Index
performance
was
dominated
by
a
handful
of
stocks,
we
expect
that
careful
selection
will
be
central
to
effective
portfolio
positioning
in
the
coming
months.
Given
the
body
of
data
supporting
higher
returns
at
companies
that
invest
in
and
nurture
gender
diversity
and
employee
satisfaction,
we
believe
companies
that
work
to
level
the
playing
field
can
generate
more
resilient
returns
regardless
of
the
economic
backdrop.
As
such,
we
remain
focused
on
identifying
those
companies
that
promote
gender
diversity
with
the
objective
of
generating
long
term
capital
growth
for
our
clients.
March
15,
2024
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
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
6
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
may,
but
is
not
required
to,
use
derivative
instruments.
A
small
investment
in
derivatives
could
have
a
potentially
large
impact
on
the
fund's
performance.
The
use
of
derivatives
involves
risks
different
from,
or
possibly
greater
than,
the
risks
associated
with
investing
directly
in
the
underlying
assets.
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.
Please
note:
the
position
in
any
security
highlighted
with
italicized
typeface
was
sold
during
the
reporting
period.
FUND
PERFORMANCE
(Unaudited)
7
Comparison
of
change
in
value
of
a
$10,000
investment
in
BNY
Mellon
Women’s
Opportunities
ETF
with
a
hypothetical
investment
of
$10,000
in
the
S&P
500
®
Index
(the
“Index”).
†
Source:
Lipper
Inc.
††
The
inception
date
is
the
first
date
the
fund
was
available
on
The
NASDAQ
Stock
Market
LLC.
Past
performance
is
not
predictive
of
future
performance.
The
above
graph
compares
a
hypothetical
$10,000
investment
made
in
BNY
Mellon
Women’s
Opportunities
ETF
on
5/17/23
to
a
hypothetical
investment
of
$10,000
made
in
the
Index
on
that
date
using
closing
market
price
return.
All
dividends
and
capital
gain
distributions
are
reinvested.
The
fund’s
performance
shown
in
the
line
graph
above
takes
into
account
all
applicable
fees
and
expenses.
The
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.
Further
information
relating
to
fund
performance,
including
expense
reimbursements,
if
applicable,
is
contained
in
the
Financial
Highlight
section
of
the
prospectus
and
elsewhere
in
this
report.
The
performance
data
quoted
represents
past
performance,
which
is
no
guarantee
of
future
results.
Share
price
and
investment
return
fluctuate
and
an
investor’s
shares
may
be
worth
more
or
less
than
original
cost
upon
redemption.
Current
performance
may
be
lower
or
higher
than
the
performance
quoted.
Go
to
www.
im.bnymellon.com
for
the
fund’s
most
recent
month-end
returns.
The
fund’s
performance
shown
in
the
graph
and
table
does
not
reflect
the
deduction
of
taxes
that
a
shareholder
would
pay
on
fund
distributions
or
the
redemption
of
fund
shares.
Average
Annual
Total
Returns
as
of
February
29,
2024
Inception
Date
††
From
Inception
BNY
Mellon
Women’s
Opportunities
ETF
Net
Asset
Value
Return
5/17/23
26.36%
Market
Price
Return
5/17/23
26.53%
S&P
500
®
Index
5/17/23
24.78%
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
8
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
table
below
shows
the
expenses
you
would
have
paid
on
a
$1,000
investment
in
the
fund
from
September
1,
2023
to
February
29,
2024.
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
February
29,
2024
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
period
ended
February
29,
2024.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
182/366
(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
1,177.80
1,022.38
2.71
2.51
0.50
STATEMENT
OF
INVESTMENTS
February
29,
2024
9
Description
Shares
Value
($)
Common
Stocks
–
99.1%
Banks
–
5.5%
Bank
of
America
Corp.
4,582
158,171
First
Horizon
Corp.
7,739
109,120
JPMorgan
Chase
&
Co.
2,252
419,007
686,298
Capital
Goods
–
3.0%
Caterpillar,
Inc.
420
140,263
Trane
Technologies
PLC
848
239,111
379,374
Commercial
&
Professional
Services
–
0.7%
Veralto
Corp.
1,031
89,099
Consumer
Discretionary
Distribution
&
Retail
–
6.0%
Amazon.com,
Inc.
(a)
4,280
756,533
Consumer
Durables
&
Apparel
–
1.4%
Lululemon
Athletica,
Inc.
(a)
390
182,165
Consumer
Services
–
2.6%
Bright
Horizons
Family
Solutions,
Inc.
(a)
2,826
324,594
Energy
–
3.5%
ConocoPhillips
1,012
113,890
Occidental
Petroleum
Corp.
2,773
168,072
Schlumberger
NV
3,384
163,549
445,511
Financial
Services
–
4.1%
Block,
Inc.,
Class
A
(a)
1,784
141,774
Mastercard,
Inc.,
Class
A
784
372,212
513,986
Food,
Beverage
&
Tobacco
–
1.7%
PepsiCo,
Inc.
1,288
212,958
Health
Care
Equipment
&
Services
–
8.7%
Addus
HomeCare
Corp.
(a)
1,152
106,307
Boston
Scientific
Corp.
(a)
4,676
309,598
Centene
Corp.
(a)
2,400
188,232
Cooper
Cos.,
Inc.
(The)
1,652
154,627
Hologic,
Inc.
(a)
1,816
134,021
Progyny,
Inc.
(a)
5,520
201,590
1,094,375
Household
&
Personal
Products
–
1.5%
Procter
&
Gamble
Co.
(The)
1,165
185,165
STATEMENT
OF
INVESTMENTS
(continued)
10
Description
Shares
Value
($)
Common
Stocks
–
99.1%
(continued)
Insurance
–
2.3%
Progressive
Corp.
(The)
1,537
291,354
Materials
–
0.9%
Constellium
SE
(a)
5,856
113,548
Media
&
Entertainment
–
5.8%
Meta
Platforms,
Inc.,
Class
A
976
478,367
Pinterest,
Inc.,
Class
A
(a)
3,204
117,586
Walt
Disney
Co.
(The)
1,248
139,252
735,205
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
10.3%
AbbVie,
Inc.
2,248
395,761
Alnylam
Pharmaceuticals,
Inc.
(a)
480
72,523
Avantor,
Inc.
(a)
5,402
133,105
Eli
Lilly
&
Co.
452
340,663
Illumina,
Inc.
(a)
1,352
189,050
Zoetis,
Inc.,
Class
A
868
172,151
1,303,253
Real
Estate
Management
&
Development
–
1.2%
CoStar
Group,
Inc.
(a)
1,779
154,826
Semiconductors
&
Semiconductor
Equipment
–
9.9%
Applied
Materials,
Inc.
1,335
269,163
Micron
Technology,
Inc.
1,757
159,202
NVIDIA
Corp.
876
693,021
Texas
Instruments,
Inc.
756
126,501
1,247,887
Software
&
Services
–
23.0%
Accenture
PLC,
Class
A
761
285,208
Akamai
Technologies,
Inc.
(a)
1,517
168,266
DoubleVerify
Holdings,
Inc.
(a)
3,869
119,513
HubSpot,
Inc.
(a)
470
290,841
Intuit,
Inc.
496
328,793
Microsoft
Corp.
2,496
1,032,445
PTC,
Inc.
(a)
658
120,421
Shopify,
Inc.,
Class
A
(a)
4,488
342,749
Workday,
Inc.,
Class
A
(a)
720
212,155
2,900,391
Transportation
–
5.6%
FedEx
Corp.
1,104
274,863
Uber
Technologies,
Inc.
(a)
5,337
424,291
699,154
Utilities
–
1.4%
Exelon
Corp.
4,896
175,473
Total
Common
Stocks
(cost
$9,830,350)
12,491,149
11
See
Notes
to
Financial
Statements
Description
Shares
Value
($)
Investment
Companies
–
0.9%
Registered
Investment
Companies
–
0.9%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.28%
(b)(c)
(cost
$107,148)
107,148
107,148
Total
Investments
(cost
$9,937,498)
100.0%
12,598,297
Cash
and
Receivables
(Net)
0.0%
4,458
Net
Assets
100.0%
12,602,755
(a)
Non-income
producing
security.
(b)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(c)
The
rate
shown
is
the
1-day
yield
as
of
February
29,
2024.
Portfolio
Summary
(Unaudited)
†
Value
(%)
Information
Technology
32.9
Health
Care
19.0
Financials
11.9
Consumer
Discretionary
10.0
Industrials
9.3
Communication
Services
5.8
Energy
3.5
Consumer
Staples
3.2
Utilities
1.4
Real
Estate
1.2
Materials
0.9
Registered
Investment
Companies
0.9
100.0
†
Based
on
net
assets.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
February
29,
2024
are
as
follows:
Description
Value
($)
5/18
/23
1
Purchases
($)
2
Sales
($)
Value
($)
2/29/24
Dividends/
Distributions
($)
Investment
Companies
–
0.9%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
678,416
(571,268)
107,148
6,410
Total
–
0.9%
—
678,416
(571,268)
107,148
6,410
1
Commencement
of
operations.
2
Includes
reinvested
dividends/distributions.
STATEMENT
OF
ASSETS
AND
LIABILITIES
February
29,
2024
12
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
–
Unaffiliated
issuers
9,830,350
12,491,149
Affiliated
issuers
107,148
107,148
Dividends
receivable
9,169
Tax
reclaim
receivable—Note
2(b)
178
12,607,644
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
4,889
4,889
Net
Assets
($)
12,602,755
Composition
of
Net
Assets
($):
Paid-in
capital
10,000,029
Total
distributable
earnings
(loss)
2,602,726
Net
Assets
($)
12,602,755
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
400,001
Net
asset
value
per
share
31.51
Market
price
per
share
31.55
STATEMENT
OF
OPERATIONS
For
the
Period
from
May
18,
2023
(commencement
of
operations)
to
February
29,
2024
13
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends
(net
of
$159
foreign
taxes
withheld
at
source):
Unaffiliated
issuers
78,673
Affiliated
issuers
6,410
Total
Income
85,083
Expenses:
Management
fee—Note
3(a)
42,577
Total
Expenses
42,577
Net
Investment
Income
42,506
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
(70,123)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
2,660,799
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
2,590,676
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
2,633,182
STATEMENT
OF
CHANGES
IN
NET
ASSETS
14
See
Notes
to
Financial
Statements
For
the
Period
from
May
18,
2023
(a)
to
February
29,
2024
Operations
($):
Net
investment
income
42,506
Net
realized
gain
(loss)
on
investments
(70,123)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
2,660,799
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
2,633,182
Distributions
($):
Distributions
to
shareholders
(30,456)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
10,000,025
Transaction
fees—Note
5
4
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
10,000,029
Total
Increase
(Decrease)
in
Net
Assets
12,602,755
Net
Assets
($):
Beginning
of
Period
—
End
of
Period
12,602,755
Changes
in
Shares
Outstanding:
Shares
sold
400,001
Net
Increase
(Decrease)
in
Shares
Outstanding
400,001
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
15
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
February
29,
2024
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
25.00
Investment
Operations:
Net
investment
income
(b)
0.11
Net
realized
and
unrealized
gain
(loss)
on
investments
6.48
Total
from
Investment
Operations
6.59
Distributions:
–
Dividends
from
net
investment
income
(0.08)
Transaction
fees
(b)
0.00
(c)
Net
asset
value,
end
of
period
31.51
Market
price,
end
of
period
31.55
Net
Asset
Value
Total
Return
(%)
(d)
26.36
(e)
Market
Price
Total
Return
(%)
(d)
26.53
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.50
(f)
Ratio
of
net
investment
income
to
average
net
assets
0.50
(f)
Portfolio
Turnover
Rate
(g)
24.71
Net
Assets,
end
of
period
($
x
1,000)
12,603
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
Amount
represents
less
than
$0.01
per
share.
(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
16
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
thirteen
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
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
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
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).
17
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.).
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.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
18
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 February
29,
2024
in
valuing
the
fund’s
investments:
19
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
February
29,
2024,
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
specific
economic
sectors,
industries
or
segments
of
the
market.
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.
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
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
12,491,149
—
—
12,491,149
Investment
Companies
107,148
—
—
107,148
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
20
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.
(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
21
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
continue
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 February
29,
2024,
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 February
29,
2024,
the
fund
did
not
incur
any
interest
or
penalties.
The
tax
year
in
the
period
ended February
29,
2024
remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities.
At February
29,
2024,
the
components
of
accumulated
earnings
on
a
tax
basis
were
as
follows:
undistributed
ordinary
income
$11,386,
accumulated
capital
losses
$69,408,
and
unrealized appreciation
$2,660,748.
The
fund is
permitted
to
carry
forward
capital
losses
for
an
unlimited
period.
Furthermore,
capital
loss
carryovers
retain
their
character
as
either
short-term
or
long-
term
capital
losses.
The
accumulated
capital
loss
carryover
is
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
February
29,
2024.
The
fund
has
$69,408
of
short-term
capital
losses
which
can
be
carried
forward
for
an
unlimited
period.
The
tax
character
of
distributions
paid
to
shareholders
during
the
fiscal
year
ended
February
29,
2024
was
as
follows:
ordinary
income
$30,456.
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,
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
22
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
February
29,
2024,
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.
(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 $4,889.
23
(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
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
February
29,
2024, amounted
to $2,816,265
and
$2,652,946,
respectively.
At February
29,
2024,
the
cost
of
investments
for
federal
income
tax
purposes
was
$9,937,549;
accordingly,
accumulated
net
unrealized
appreciation on
investments
for
federal
income
tax
purposes
was
$2,660,748,
consisting
of
gross
appreciation
of
$2,860,412
and
gross
depreciation
of
$199,664.
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
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
24
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
February
29,
2024,
MBC
Investments
Corporation,
a
wholly-
owned
subsidiary
of
BNY
Mellon,
held
381,701
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
February
29,
2024,
the
fund
had
in-kind
transactions
associated
with
creations
of
$9,737,212
and
redemptions
of
$0.
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
25
To
the
Shareholders
and
the
Board
of
Trustees
of
BNY
Mellon
Women’s
Opportunities
ETF
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
BNY
Mellon
Women’s
Opportunities
ETF
(the
“Fund”)
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust
(the
“Trust”)),
including
the
statement
of
investments,
as
of
February
29,
2024,
and
the
related
statements
of
operations,
changes
in
net
assets,
and
the
financial
highlights
for
the
period
from
May
18,
2023
(commencement
of
operations)
through
February
29,
2024
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Fund
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust)
at
February
29,
2024,
the
results
of
its
operations,
the
changes
in
its
net
assets
and
its
financial
highlights
for
the
period
from
May
18,
2023
(commencement
of
operations)
through
February
29,
2024,
in
conformity
with
U.S.
generally
accepted
accounting
principles.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Trust’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Fund’s
financial
statements
based
on
our
audit.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
("PCAOB")
and
are
required
to
be
independent
with
respect
to
the
Trust
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
conducted
our
audit
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audit
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Trust
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
the
Trust’s
internal
control
over
financial
reporting.
As
part
of
our
audit,
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Trust’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audit
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
February
29,
2024,
by
correspondence
with
the
custodian,
brokers
and
others;
when
replies
were
not
received
from
brokers
and
others,
we
performed
other
auditing
procedures.
Our
audit
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
We
believe
that
our
audit
provides
a
reasonable
basis
for
our
opinion.
We
have
served
as
the
auditor
of
one
or
more
investment
companies
in
the
BNY
Mellon
Family
of
Funds
since
at
least
1957,
but
we
are
unable
to
determine
the
specific
year.
New
York,
New
York
April
19,
2024
IMPORTANT
TAX
INFORMATION
(Unaudited)
26
Form
1099-DIV,
Form
1042-S
and
other
year–end
tax
information
provide
shareholders
with
actual
calendar
year
amounts
that
should
be
included
in
their
tax
returns.
Shareholders
should
consult
their
tax
advisers.
The
following
distribution
information
is
being
provided
as
required
by
the
Internal
Revenue
Code
or
to
meet
a
specific
state’s
requirement.
The
fund
designates
the
following
amounts
or,
if
subsequently
determined
to
be
different,
the
maximum
amount
allowable
for
its
fiscal
year
ended February
29,
2024:
For
federal
tax
purposes
the
fund
hereby
reports
100%
of
ordinary
income
dividends
paid
during
the
fiscal
year
ended
February
29,
2024 as
qualified
dividend
income
and
corporate
dividends
received
deduction.
LIQUIDITY
RISK
MANAGEMENT
PROGRAM
(Unaudited)
27
The
funds
of
the
Trust
have
adopted
a
liquidity
risk
management
program
(the
“Program”)
pursuant
to
the
requirements
of
Rule
22e-4
under
the
Investment
Company
Act
of
1940,
as
amended.
Rule
22e-4
requires
registered
open-end
funds,
including
exchange-traded
funds,
to
establish
liquidity
risk
management
programs
in
order
to
effectively
manage
fund
liquidity
and
shareholder
redemptions.
The
rule
is
designed
to
mitigate
the
risk
that
a
fund
could
not
meet
redemption
requests
without
significantly
diluting
the
interests
of
remaining
investors.
The
Board
has
appointed
BNY
Mellon
ETF
Investment
Adviser,
LLC,
the
investment
adviser
to
the
funds,
as
the
Program
Administrator.
The
rule
requires
each
fund
to
assess,
manage
and
review
its
liquidity
risk
at
least
annually,
considering
applicable
factors
such
as
investment
strategy
and
liquidity
during
normal
and
reasonably
foreseeable
stressed
conditions,
including
whether
the
strategy
is
appropriate
for
an
open-end
fund
and
whether
the
fund
has
a
relatively
concentrated
portfolio
or
large
positions
in
particular
issuers.
Each
fund
must
also
assess
its
use
of
borrowings
and
derivatives,
short-
term
and
long-term
cash
flow
projections
in
normal
and
reasonably
foreseeable
stressed
conditions,
holdings
of
cash
and
cash
equivalents,
and
borrowing
arrangements
and
other
funding
sources.
In
addition,
with
respect
to
an
exchange-traded
fund,
a
fund
must
assess
the
relationship
between
the
fund’s
portfolio
liquidity
and
the
way
in
which,
and
the
prices
and
spreads
at
which,
the
fund’s
shares
trade,
and
the
effect
of
the
composition
of
baskets
on
the
overall
liquidity
of
the
fund’s
portfolio.
The
rule
also
generally
requires
funds
to
classify
each
of
their
investments
as
highly
liquid,
moderately
liquid,
less
liquid
or
illiquid
based
on
the
number
of
days
the
fund
expects
it
would
take
to
liquidate
the
investment,
and
to
review
these
classifications
at
least
monthly
or
more
often
under
certain
conditions.
Illiquid
investments
are
those
a
fund
does
not
expect
to
be
able
to
sell
or
dispose
of
within
seven
calendar
days
without
the
sale
or
disposition
significantly
changing
the
market
value
of
the
investment.
A
fund
is
prohibited
from
acquiring
an
investment
if,
after
the
acquisition,
its
holdings
of
illiquid
assets
will
exceed
15%
of
its
net
assets.
In
addition,
if
a
fund
permits
redemptions
in-kind,
the
rule
requires
the
fund
to
establish
redemption
in-kind
policies
and
procedures
governing
how
and
when
it
will
engage
in
such
redemptions.
Pursuant
to
the
rule’s
requirements,
the
Program
has
been
reviewed
and
approved
by
the
Board.
Furthermore,
at
its
November
2023
meeting,
the
Board
received
a
written
report
prepared
by
the
Program
Administrator,
for
the
period
October
1,
2022
to
September
30,
2023,
addressing
the
operation
of
the
Program,
assessing
the
Program’s
adequacy
and
effectiveness
and
describing
any
material
changes
made
to
the
Program.
LIQUIDITY
RISK
MANAGEMENT
PROGRAM
(Unaudited)
(continued)
28
Assessment
of
Program
In
the
opinion
of
the
Program
Administrator,
the
Program
approved
by
the
Board
continues
to
be
adequate
for
the
funds
and
the
Program
has
been
implemented
effectively.
The
Program
Administrator
has
monitored
each
fund’s
liquidity
risk
and
the
liquidity
classification
of
the
securities
held
by
the
funds
and
has
determined
that
the
Program
is
operating
effectively.
During
the
period
from
October
31,
2022
to
September
30,
2023,
there
were
no
material
changes
to
the
Program
and
no
material
liquidity
events
that
impacted
the
funds.
During
the
period,
each
fund
held
sufficient
highly
liquid
assets
to
meet
fund
redemptions.
Under
normal
expected
foreseeable
fund
redemption
forecasts
and
foreseeable
stressed
fund
redemption
forecasts,
the
Program
Administrator
believes
that
each
fund
maintains
sufficient
highly
liquid
assets
to
meet
expected
fund
redemptions.
BOARD
MEMBERS
INFORMATION
(Unaudited)
INDEPENDENT
BOARD
MEMBERS
29
J.
Charles
Cardona
(68)
Chairman
of
the
Board
(2020)
Principal
Occupation
During
Past
5
Years:
BNY
Mellon
Family
of
Funds,
Interested
Director
(2014-2018),
Independent
Director
(2019-Present)
BNY
Mellon
Liquidity
Funds,
Director
(2004-Present)
and
Chairman
(2019-2021)
No.
of
Portfolios
for
which
Board
Member
Serves:
35,
including
19
managed
by
an
affiliate
of
the
Adviser
Kristen
M.
Dickey
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Independent
board
director
of
Marstone,
Inc.,
a
financial
technology
company
(since
2018);
Lead
non-executive
director
for
Aperture
Investors,
LLC,
an
investment
management
firm
(since
2018);
Managing
Director—Global
Head
of
Index
Strategy
at
BlackRock,
Inc.
(until
2017).
No.
of
Portfolios
for
which
Board
Member
Serves:
13
F.
Jack
Liebau,
Jr.
(60)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
Director
at
Beach
Investment
Counsel,
a
financial
advisory
firm
(since
2020)
Corporate
director
(since
2015)
Other
Public
Company
Board
Memberships
During
Past
5
Years:
Myers
Industries,
an
industrial
company,
Director
(2015
–
Present)
and
Chairman
of
Board
(2016
–
Present)
STRATTEC
Security
Corp.,
an
automotive
power
and
security
solutions
company,
Director
(2023
–
Present)
and
Chairman
of
Board
(2024
–
Present)
No.
of
Portfolios
for
which
Board
Member
Serves:
13
Jill
I.
Mavro
(51)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
director
at
Ecoban
Securities,
LLC,
a
financial
technology
consulting
company
(since
2020)
Founder
and
Principal
of
Spoondrift
Advisory,
LLC
(since
2018);
Senior
Managing
Director,
Head
of
Strategic
Relationships
and
Member
of
SPDR
Executive
Committee
at
State
Street
Global
Advisors
(until
2018)
No.
of
Portfolios
for
which
Board
Member
Serves:
13
30
BOARD
MEMBERS
INFORMATION
(Unaudited)
(continued)
INDEPENDENT
BOARD
MEMBERS
Kevin
W.
Quinn
(64)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Partner
at
PricewaterhouseCoopers,
LLC
(until
2019)
No.
of
Portfolios
for
which
Board
Member
Serves:
13
Stacy
L.
Schaus
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Chief
Executive
Officer
of
the
Schaus
Group
LLC,
a
consulting
firm
(since
2019);
Advisory
board
member
of
A&P
Capital,
a
consulting
firm
(from
2019-2021);
Executive
Vice
President—Defined
Contribution
Practice
Founder
at
PIMCO
Investment
Management
(until
2018).
No.
of
Portfolios
for
which
Board
Member
Serves:
13
The
address
of
the
Board
Members
and
Officers
is
c/o
BNY
Mellon
ETF
Investment
Adviser,
LLC,
240
Greenwich
Street,
New
York,
New
York
10286.
Additional
information
about
each
Board
Member
is
available
in
the
fund’s
Statement
of
Additional
Information
which
can
be
obtained
from
the
Adviser
free
of
charge
by
calling
this
toll
free
number:
1-833-383-2696.
OFFICERS
OF
THE
TRUST
(Unaudited)
31
DAVID
DIPETRILLO,
President
since
February
2020.
Vice
President
and
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2021;
Head
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
February
2023;
Head
of
North
America
Product,
BNY
Mellon
Investment
Management
from
January
2018
to
February
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
99
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
46
years
old
and
has
been
an
employee
of
BNY
Mellon
since
2005.
PETER
M.
SULLIVAN,
Chief
Legal
Officer
since
July
2021,
Vice
President
and
Assistant
Secretary
since
February
2020.
Chief
Legal
Officer
of
BNY
Mellon
Investment
Adviser,
Inc.
and
Associate
General
Counsel
of
BNY
Mellon
since
July
2021;
Senior
Managing
Counsel
of
BNY
Mellon
from
December
2020
to
July
2021;
and
Managing
Counsel
of
BNY
Mellon
from
March
2009
to
December
2020.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
since
April
2004.
JAMES
WINDELS,
Treasurer
since
February
2020.
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2023;
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
September
2020;
and
Director
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
65
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1985.
SARAH
S.
KELLEHER,
Vice
President
and
Secretary
since
February
2020.
Vice
President
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
since
February
2020;
Senior
Managing
Counsel
of
BNY
Mellon
since
September
2021;
and
Managing
Counsel
of
BNY
Mellon
from
December
2017
to
September
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
48
years
old
and
has
been
an
employee
of
BNY
Mellon
since
March
2013.
JAMES
BITETTO,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon
since
December
2019;
Managing
Counsel
of
BNY
Mellon
from
April
2014
to
December
2019;
and
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
57
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
December
1996.
DEIRDRE
CUNNANE,
Vice
President
and
Assistant
Secretary
since
February
2020.
Managing
Counsel
of
BNY
Mellon
since
December
2021;
and
Counsel
of
BNY
Mellon
from
August
2018
to
December
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
32
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
August
2018.
JEFF
PRUSNOFSKY,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
58
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
October
1990.
OFFICERS
OF
THE
TRUST
(Unaudited)
(continued)
32
AMANDA
QUINN,
Vice
President
and
Assistant
Secretary
since
February
2020.
Counsel
of
BNY
Mellon
since
June
2019;
and
Regulatory
Administration
Manager
at
BNY
Mellon
Investment
Management
Services from
September
2018
to
May
2019.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
June
2012.
JOANNE
SKERRETT,
Vice
President
and
Assistant
Secretary
since
March
2023.
Managing
Counsel
of
BNY
Mellon
since
June
2022;
and
Senior
Counsel
with
the
Mutual
Fund
Directors
Forum,
a
leading
funds
industry
organization,
from
2016
to
June
2022.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
51
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
2022.
DANIEL
GOLDSTEIN,
Vice
President
since
March
2022
Head
of
Product
Development
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023;
and
Senior
Vice
President,
Development
&
Oversight
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
99
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
the
Distributor
since
1991.
JOSEPH
MARTELLA,
Vice
President
since
March
2022
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
December
2022;
Head
of
Product
Management
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023,
and
Senior
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
99
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
47
years
old
and
has
been
an
employee
of
the
Distributor
since
1999.
GAVIN
C.
REILLY,
Assistant
Treasurer
since
February
2020.
Tax
Manager-BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1991.
ROBERT
SALVIOLO,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
1989.
ROBERT
SVAGNA,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
November
1990.
33
NATALYA
ZELENSKY,
Vice
President
and
Assistant
Secretary
since
February
2020
and
Chief
Compliance
Officer
since
August
2021.
Chief
Compliance
Officer
since
August
2021
and
Vice
President
since
February
2020
of
BNY
Mellon
ETF
Investment
Adviser,
LLC;
Managing
Counsel
of
BNY
Mellon
from
December
2019
to
August
2021;
Counsel
of
BNY
Mellon
from
May
2016
to
December
2019;
and
Assistant
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
from
April
2018
to
August
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
117
portfolios)
managed
by
the
Adviser or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
May
2016.
CARIDAD
M.
CAROSELLA,
Anti-Money
Laundering
Compliance
Officer
since
February
2020.
Anti-Money
Laundering
Compliance
Officer
of
the
BNY
Mellon
Family
of
Funds
and
BNY
Mellon
Funds
Trust.
She
is
an
officer
of
47
investment
companies
(comprised
of
110
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
55
years
old
and
has
been
an
employee
of
the
Distributor
since
1997.
For
More
Information
2024
BNY
Mellon
Securities
Corporation
4868AR0224
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.
(a) As of the period ended February 29, 2024 (the “Reporting Period”), the Registrant has adopted a code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, principal accounting officer, controller or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party.
(c) During the Reporting Period, there have been no amendments to a provision of the code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party, and that relates to any element of the code of ethics description.
(d) During the Reporting Period, the Registrant has not granted any waivers, including an implicit waiver, from a provision of the code of ethics to the Registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Registrant or a third party, that relates to one or more of the items set forth in paragraph (b) of this item’s instructions.
Item 3. Audit Committee Financial Expert.
The Registrant’s Board of Trustees has determined that Mr. Kevin W. Quinn is qualified to serve as an audit committee financial expert serving on the Registrant’s audit committee and that he is “independent,” as defined by Item 3 of Form N-CSR.
Item 4. Principal Accountant Fees and Services.
(a) Audit Fees
The aggregate fees billed for the period May 18, 2023 (commencement of operations) through February 29, 2024 for professional services rendered by the principal accountant for the audit of the Registrant’s annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements was $39,536.
(b) Audit-Related Fees
The aggregate fees billed for the period May 18, 2023 (commencement of operations) through February 29, 2024 for assurance and related services rendered to the Registrant by the principal accountant that are reasonably related to the performance of the audit of the Registrant’s financial statements and are not reported under paragraph (a) of this Item was $12,484. These services consisted of security counts required by Rule 17f-2 under the 1940 Act.
(c) Tax Fees
The aggregate fees billed for the period May 18, 2023 (commencement of operations) through February 29, 2024 for professional services rendered to the Registrant by the principal accountant for tax compliance, tax advice and tax planning was $7,908. These services consisted
of (i) review or preparation of U.S. federal, state, local and excise tax returns; (ii) U.S. federal, state and local entity tax planning, advice and assistance regarding statutory, regulatory or administrative developments, and (iii) tax advice regarding tax qualification
.
(d) All Other Fees
The aggregate fees billed for the period May 18, 2023 (commencement of operations) through February 29, 2024 for products and services provided by the principal accountant, other than the services reported in paragraphs (a) through (c) of this Item was $0.
(e)(1) Pursuant to the Registrant’s Audit Committee Charter that has been adopted by the audit committee, the audit committee shall approve all audit and permissible non-audit services to be provided to the Registrant and all permissible non-audit services to be provided to its investment adviser or any entity controlling, controlled by or under common control with the investment adviser that provides ongoing services to the Registrant if the engagement relates directly to the operations and financial reporting of the Registrant.
(e)(2) The percentage of services described in paragraphs (b) through (d) of this Item that were approved by the audit committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, with respect to: Audit-Related Fees was 100%; Tax Fees was 100%; and All Other Fees was 0%.
(f) The percentage of hours expended on the principal accountant’s engagement to audit the Registrant’s financial statements for the most recent fiscal year that were attributed to work performed by persons other than the principal accountant’s full-time, permanent employees was less than fifty percent.
(g) The aggregate non-audit fees billed by the Registrant’s accountant for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the Registrant for the period May 18, 2023 (commencement of operations) through February 29, 2024 of the Registrant was $280,962.
(h) The Registrant’s audit committee has considered whether the provision of non-audit services that were rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the Registrant that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X is compatible with maintaining the principal accountant’s independence.
(i) Not applicable.
(j) Not applicable.
Item 5. Audit Committee of Listed Registrants.
(a) The Registrant has a separately designated audit committee established in accordance with Section 3(a)(58)(A) of the Securities Exchange Act of 1934, as amended, which consists of independent trustees of the Registrant. The audit committee members are J. Charles Cardona, Kristen M. Dickey, F. Jack Liebau, Jr., Jill I. Mavro, Kevin W. Quinn, and Stacy L. Schaus.
(b) 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 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)
(a)(2)
(a)(2)(1) Not applicable.
(a)(2)(2) Not applicable.
(b)
Certifications pursuant to Rule 30a-2(b) under the 1940 Act and Section 906 of the Sarbanes-Oxley Act of 2002 are attached hereto.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
(Registrant) BNY Mellon ETF Trust
By (Signature and Title)* /s/ David J. DiPetrillo
David J. DiPetrillo, President
David J. DiPetrillo, President
(Principal Executive Officer)
Date 04/23/2024
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 04/23/2024 ___________
By (Signature and Title)* /s/ James Windels ______
James Windels, Treasurer
James Windels, Treasurer
(Principal Financial and Accounting Officer)
Date 04/22/2024
*
Print the name and title of each signing officer under his or her signature.