UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number 811-23477
BNY Mellon ETF Trust
(Exact name of registrant as specified in charter)
(Exact name of registrant as specified in charter)
240 Greenwich Street
New York, New York 10286
(Address of principal executive offices) (Zip code)
(Address of principal executive offices) (Zip code)
Deirdre Cunnane, Esq.
240 Greenwich Street
New York, New York 10286
(Name and address of agent for service)
Registrant's telephone number, including area code: (212) 922-6400
Date of fiscal year end: February 28
Date of reporting period: August 31, 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 ETF
BNY Mellon Women’s Opportunities ETF
Item 1. Reports to Stockholders.
(a) The following is a copy of the report transmitted to shareholders pursuant to Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1).
BNY Mellon Innovators ETF
Semi-Annual Shareholder Report
August 31, 2024
Ticker - BKIV (The NASDAQ Stock Market LLC)
This semi-annual shareholder report contains important information about BNY Mellon Innovators ETF (the “Fund”) for the period of March 1, 2024 to August 31, 2024. You can find additional information about the Fund at bny.com/investments/etfliterature. You can also request this information by calling us at 1-833-383-2696 or calling your financial adviser.
What were the Fund's costs for the last six months?
(based on a hypothetical $10,000 investment)
| Fund | Costs of a $10,000 investment | Costs paid as a percentage of a $10,000 investment |
|---|---|---|
| BNY Mellon Innovators ETF | $26 | 0.50%Footnote Reference* |
| Footnote | Description |
Footnote* | Annualized |
KEY FUND STATISTICS (AS OF 8/31/24)
| Fund size (Millions) | Number of Holdings | Portfolio Turnover |
|---|---|---|
| $15 | 51 | 25.96% |
Portfolio Holdings (as of 8/31/24)
Top Ten Holdings
(Based on Net Assets)*
| Value | Value |
|---|---|
| NVIDIA Corp. - | 13.6% |
| Alphabet, Inc., Class C - | 5.1% |
| Insmed, Inc. - | 4.4% |
| CoStar Group, Inc. - | 3.7% |
| Netflix, Inc. - | 3.6% |
| Inspire Medical Systems, Inc. - | 3.0% |
| Repligen Corp. - | 3.0% |
| Klaviyo, Inc., Class A - | 2.9% |
| Sarepta Therapeutics, Inc. - | 2.7% |
| Freshpet, Inc. - | 2.5% |
*Excludes money market funds or other short-term securities held for the investment of cash and cash collateral for securities loaned, if any.
Not FDIC-Insured. Not Bank-Guaranteed. May Lose Value.
Sector Allocation
(Based on Net Assets)
| Value | Value |
|---|---|
| Net Other Assets and Liabilities | 0.0% |
| Investment Companies | 0.6% |
| Energy | 1.7% |
| Financials | 3.1% |
| Real Estate | 3.7% |
| Consumer Staples | 5.6% |
| Consumer Discretionary | 6.4% |
| Communication Services | 13.7% |
| Information Technology | 28.4% |
| Health Care | 36.8% |
For additional information about the Fund, including its prospectus, financial information, portfolio holdings and proxy voting information, please visit bny.com/investments/etfliterature.
© 2024 BNY Mellon Securities Corporation,
240 Greenwich Street, 9th Floor, New York, NY 10286
Code-4867SA0824
BNY Mellon Women's Opportunities ETF
Semi-Annual Shareholder Report
August 31, 2024
Ticker - BKWO (The NASDAQ Stock Market LLC)
This semi-annual shareholder report contains important information about BNY Mellon Women's Opportunities ETF (the “Fund”) for the period of March 1, 2024 to August 31, 2024. You can find additional information about the Fund at bny.com/investments/etfliterature. You can also request this information by calling us at 1-833-383-2696 or calling your financial adviser.
What were the Fund's costs for the last six months?
(based on a hypothetical $10,000 investment)
| Fund | Costs of a $10,000 investment | Costs paid as a percentage of a $10,000 investment |
|---|---|---|
| BNY Mellon Women's Opportunities ETF | $26 | 0.50%Footnote Reference* |
| Footnote | Description |
Footnote* | Annualized |
KEY FUND STATISTICS (AS OF 8/31/24)
| Fund size (Millions) | Number of Holdings | Portfolio Turnover |
|---|---|---|
| $13 | 50 | 19.07% |
Portfolio Holdings (as of 8/31/24)
Top Ten Holdings
(Based on Net Assets)*
| Value | Value |
|---|---|
| Microsoft Corp. - | 8.2% |
| NVIDIA Corp. - | 7.8% |
| Amazon.com, Inc. - | 5.7% |
| Apple, Inc. - | 5.1% |
| JPMorgan Chase & Co. - | 3.8% |
| Meta Platforms, Inc., Class A - | 3.4% |
| AbbVie, Inc. - | 3.2% |
| Eli Lilly & Co. - | 2.9% |
| Uber Technologies, Inc. - | 2.9% |
| Mastercard, Inc., Class A - | 2.8% |
*Excludes money market funds or other short-term securities held for the investment of cash and cash collateral for securities loaned, if any.
Not FDIC-Insured. Not Bank-Guaranteed. May Lose Value.
Sector Allocation
(Based on Net Assets)
| Value | Value |
|---|---|
| Net Other Assets and Liabilities | 0.0% |
| Materials | 0.7% |
| Real Estate | 1.0% |
| Investment Companies | 1.1% |
| Utilities | 1.7% |
| Energy | 3.1% |
| Consumer Staples | 3.8% |
| Communication Services | 5.0% |
| Consumer Discretionary | 9.3% |
| Industrials | 10.1% |
| Financials | 11.3% |
| Health Care | 18.9% |
| Information Technology | 34.0% |
For additional information about the Fund, including its prospectus, financial information, portfolio holdings and proxy voting information, please visit bny.com/investments/etfliterature.
© 2024 BNY Mellon Securities Corporation,
240 Greenwich Street, 9th Floor, New York, NY 10286
Code-4868SA0824
Item 1. Reports to Stockholders (cont.).
(b) Not applicable.
Item 2. Code of Ethics.
Not applicable.
Item 3. Audit Committee Financial Expert.
Not applicable.
Item 4. Principal Accountant Fees and Services.
Not applicable.
Item 5. Audit Committee of Listed Registrants.
Not applicable.
Item 6. Investments.
(a) The Schedule of Investments in securities of unaffiliated issuers as of the close of the Reporting Period is included in the financial statements filed under Item 7 of this Form N-CSR.
(b) Not applicable.
Item 7. Financial Statements and Financial Highlights for Open-End Management Investment Companies.
The following is a copy of the Registrant’s most recent financial statements and financial highlights.
BNY
Mellon
ETF
Trust
SEMI-ANNUAL
FINANCIALS
AND
OTHER
INFORMATION
August
31,
2024
BNY
Mellon
Innovators
ETF:
BKIV
Principal
U.S.
Listing
Exchange:
The
NASDAQ
Stock
Market
LLC
IMPORTANT
NOTICE
–
CHANGES
TO
ANNUAL
AND
SEMI-ANNUAL
REPORTS
The
Securities
and
Exchange
Commission
(the
“SEC”)
has
adopted
rule
and
form
amendments
which
have
resulted
in
changes
to
the
design
and
delivery
of
annual
and
semi-annual
fund
reports
(“Reports”).
Reports
are
now
streamlined
to
highlight
key
information.
Certain
information
previously
included
in
Reports,
including
financial
statements,
no
longer
appear
in
the
Reports
but
will
be
available
online
within
the
Semi-Annual
and
Annual
Financials
and
Other
Information,
delivered
free
of
charge
to
shareholders
upon
request,
and
filed
with
the
SEC.
Contents
The
Fund
Please
note
the
Semi-Annual
Financials
and
Other
Information
only
contains
Items
7-11
required
in
Form
N-CSR.
All
other
required
items
will
be
filed
with
the
SEC.
Item
7.
Financial
Statements
and
Financial
Highlights
for
Open-End
Management
Investment
Companies
3
Statement
of
Investments
3
Statement
of
Assets
and
Liabilities
5
Statement
of
Operations
6
Statement
of
Changes
in
Net
Assets
7
Financial
Highlights
8
Notes
to
Financial
Statements
9
Item
8.
Changes
in
and
Disagreements
with
Accountants
for
Open-End
Management
Investment
Companies
14
Item
9.
Proxy
Disclosures
for
Open-End
Management
Investment
Companies
15
Item
10.
Remuneration
Paid
to
Directors,
Officers,
and
Others
of
Open-End
Investment
Companies
16
Item
11.
Statement
Regarding
Basis
for
Approval
of
Investment
Advisory
Contracts
17
Save
time.
Save
paper.
View
your
next
shareholder
report
online
as
soon
as
it’s
available.
Log
into
www.bny.com/investments
and
sign
up
for
eCommunications.
It’s
simple
and
only
takes
a
few
minutes.
The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
•
Not
Bank-Guaranteed
•
May
Lose
Value
3
BNY
Mellon
Innovators
ETF
Statement
of
Investments
August
31,
2024
(Unaudited)
Item
7.
Financial
Statements
and
Financial
Highlights
for
Open-End
Management
Investment
Companies
Description
Shares
Value
($)
Common
Stocks
–
99.4%
Banks
–
1.1%
JPMorgan
Chase
&
Co.
692
155,562
Consumer
Discretionary
Distribution
&
Retail
–
1.2%
Chewy,
Inc.,
Class
A
(a)
6,352
181,349
Consumer
Durables
&
Apparel
–
1.5%
Lululemon
Athletica,
Inc.
(a)
849
220,290
Consumer
Services
–
3.7%
Airbnb,
Inc.,
Class
A
(a)
1,525
178,898
DraftKings,
Inc.,
Class
A
(a)
4,816
166,152
Dutch
Bros,
Inc.,
Class
A
(a)
6,456
200,136
545,186
Energy
–
1.7%
Cactus,
Inc.,
Class
A
4,275
254,448
Financial
Services
–
2.0%
Block,
Inc.,
Class
A
(a)
4,376
289,166
Food,
Beverage
&
Tobacco
–
5.6%
Celsius
Holdings,
Inc.
(a)(b)
7,465
283,894
Freshpet,
Inc.
(a)(b)
2,746
373,456
Vital
Farms,
Inc.
(a)
5,341
167,974
825,324
Health
Care
Equipment
&
Services
–
14.8%
Align
Technology,
Inc.
(a)
1,528
362,472
DexCom,
Inc.
(a)
3,993
276,875
Guardant
Health,
Inc.
(a)
4,929
126,084
Inspire
Medical
Systems,
Inc.
(a)
2,464
443,076
Intuitive
Surgical,
Inc.
(a)
715
352,230
iRhythm
Technologies,
Inc.
(a)
1,496
106,037
Privia
Health
Group,
Inc.
(a)
6,492
130,749
PROCEPT
BioRobotics
Corp.
(a)
1,065
84,135
TransMedics
Group,
Inc.
(a)
1,780
299,147
2,180,805
Media
&
Entertainment
–
13.7%
Alphabet,
Inc.,
Class
C
4,532
748,278
Liberty
Media
Corp.-Liberty
Formula
One,
Class
C
(a)
2,974
232,121
Netflix,
Inc.
(a)
748
524,610
Reddit,
Inc.,
Class
A
(a)
3,508
210,585
Trade
Desk,
Inc.
(The),
Class
A
(a)
2,939
307,214
2,022,808
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
22.0%
Alnylam
Pharmaceuticals,
Inc.
(a)
1,139
299,204
Ascendis
Pharma
A/S,
ADR
(a)
2,002
277,177
Crinetics
Pharmaceuticals,
Inc.
(a)
2,332
123,736
Denali
Therapeutics,
Inc.
(a)
5,554
135,740
Grail,
Inc.
(a)
3,482
49,131
Illumina,
Inc.
(a)
1,673
219,832
Insmed,
Inc.
(a)
8,426
644,336
Keros
Therapeutics,
Inc.
(a)
2,382
108,024
Natera,
Inc.
(a)
2,004
236,993
Pacific
Biosciences
of
California,
Inc.
(a)
42,549
58,292
Repligen
Corp.
(a)(b)
2,916
440,112
Sarepta
Therapeutics,
Inc.
(a)
2,907
394,712
Twist
Bioscience
Corp.
(a)(b)
4,124
178,322
4
Statement
of
Investments
(continued)
See
Notes
to
Statement
of
Investments
Description
Shares
Value
($)
Common
Stocks
–
99.4%
(continued)
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
22.0%
(continued)
Xenon
Pharmaceuticals,
Inc.
(a)
1,879
75,799
3,241,410
Real
Estate
Management
&
Development
–
3.7%
CoStar
Group,
Inc.
(a)
7,010
541,873
Semiconductors
&
Semiconductor
Equipment
–
13.6%
NVIDIA
Corp.
16,708
1,994,434
Software
&
Services
–
14.1%
Confluent,
Inc.,
Class
A
(a)
14,361
304,740
CyberArk
Software
Ltd.
(a)
767
219,930
HubSpot,
Inc.
(a)
182
90,831
Klaviyo,
Inc.,
Class
A
(a)
13,528
425,591
Monday.com
Ltd.
(a)
1,141
303,380
MongoDB,
Inc.,
Class
A
(a)
674
195,992
Shopify,
Inc.,
Class
A
(a)
3,624
268,430
Snowflake,
Inc.,
Class
A
(a)
2,329
266,042
2,074,936
Technology
Hardware
&
Equipment
–
0.7%
Pure
Storage,
Inc.,
Class
A
(a)
1,932
99,092
Total
Common
Stocks
(cost
$11,570,119)
14,626,683
Investment
Companies
–
0.6%
Registered
Investment
Companies
–
0.6%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.27%
(c)(d)
(cost
$81,938)
81,938
81,938
Total
Investments
(cost
$11,652,057)
100.0%
14,708,621
Liabilities,
Less
Cash
and
Receivables
0.0%
(4,721)
Net
Assets
100.0%
14,703,900
ADR—American
Depositary
Receipt
(a)
Non-income
producing
security.
(b)
Security,
or
portion
thereof,
on
loan.
At
August
31,
2024,
the
value
of
the
fund’s
securities
on
loan
was
$877,528
and
the
value
of
the
collateral
was
$890,291,
consisting
of
U.S.
Government
&
Agency
securities.
In
addition,
the
value
of
collateral
may
include
pending
sales
that
are
also
on
loan.
(c)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(d)
The
rate
shown
is
the
1-day
yield
as
of
August
31,
2024.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
August
31,
2024
are
as
follows:
Description
Value
($)
2/29/24
Purchases
($)
1
Sales
($)
Value
($)
8/31/24
Dividends/
Distributions
($)
Investment
Companies
–
0.6%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
228,888
1,445,524
(1,592,474)
81,938
4,431
Investment
of
Cash
Collateral
for
Securities
Loaned
–
0.0%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
180,158
2,806,056
(2,986,214)
—
968
2
Total
–
0.6%
409,046
4,251,580
(4,578,688)
81,938
5,399
1
Includes
reinvested
dividends/distributions.
2
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.
5
STATEMENT
OF
ASSETS
AND
LIABILITIES
August
31,
2024
(Unaudited)
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments
(including
securities
on
loan,
valued
at
$877,528)—Note
2(b
):
–
Unaffiliated
issuers
11,570,119
14,626,683
Affiliated
issuers
81,938
81,938
Dividends
receivable
1,103
Securities
lending
income
receivable
308
14,710,032
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—Note
3(b)
6,132
6,132
Net
Assets
($)
14,703,900
Composition
of
Net
Assets
($):
Paid-in
capital
11,404,422
Total
distributable
earnings
(loss)
3,299,478
Net
Assets
($)
14,703,900
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
450,001
Net
asset
value
per
share
32.68
Market
price
per
share
32.70
6
STATEMENT
OF
OPERATIONS
Six
Months
Ended
August
31,
2024
(Unaudited)
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Unaffiliated
issuers
8,981
Affiliated
issuers
4,431
Income
from
securities
lending—Note
2(b
)
968
Total
Income
14,380
Expenses:
Management
fee—Note
3(a)
36,105
Total
Expenses
36,105
Net
Investment
(Loss)
(21,725)
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
304,252
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
458,501
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
762,753
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
741,028
7
STATEMENT
OF
CHANGES
IN
NET
ASSETS
See
Notes
to
Financial
Statements
Six
Months
Ended
August
31,
2024
(Unaudited)
For
the
Period
from
May
18,
2023
(a)
to
February
29,
2024
Operations
($):
Net
investment
(loss)
(21,725)
(29,129)
Net
realized
gain
(loss)
on
investments
304,252
(20,599)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
458,501
2,598,063
Net
Increase
from
Payment
by
Affiliate
—
3,973
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
741,028
2,552,308
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
—
11,410,535
Transaction
fees—Note
5
—
29
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
—
11,410,564
Total
Increase
(Decrease)
in
Net
Assets
741,028
13,962,872
Net
Assets
($):
Beginning
of
Period
13,962,872
—
End
of
Period
14,703,900
13,962,872
Changes
in
Shares
Outstanding:
Shares
sold
—
450,001
Net
Increase
(Decrease)
in
Shares
Outstanding
—
450,001
(a)
Commencement
of
operations.
8
FINANCIAL
HIGHLIGHTS
See
Notes
to
Financial
Statements
Six
Months
Ended
August
31,
2024
(Unaudited)
For
the
Period
from
May
18,
2023
(a)
to
February
29,
2024
Per
Sh
are
Data
($):
Net
asset
value,
beginning
of
period
31.03
25.00
Investment
Operations:
Net
investment
(loss)
(b)
(0.05)
(0.07)
Net
realized
and
unrealized
gain
(loss)
on
investments
1.70
6.09
Payment
by
Affiliate
—
0.01
(c)
Total
from
Investment
Operations
1.65
6.03
Transaction
fees
(b)
—
0.00
(d)
Net
asset
value,
end
of
period
32.68
31.03
Market
price,
end
of
period
32.70
30.98
Net
Asset
Value
Total
Return
(%)
(e)
5.31
24.11
(f)
Market
Price
Total
Return
(%)
(e)
5.55
23.92
(f)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.50
(g)
0.50
(g)
Ratio
of
net
investment
(loss)
to
average
net
assets
(0.30)
(g)
(0.33)
(g)
Portfolio
Turnover
Rate
(h)
25.96
12.39
Net
Assets,
end
of
period
($
x
1,000)
14,704
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.
(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.
9
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
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
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”),
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
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-adviser.
NIMNA
has
entered
into
a
sub-sub-investment
advisory
agreement
with
its
affiliate,
Newton
Investment
Management
Limited
(“NIM”),
which
enables
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
NIMNA
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.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“Fund
Shares.”
Fund
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).
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
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.
10
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
equity
securities,
including
ETFs
(but
not
including
investments
in
other
open-end
registered
investment
companies),
generally
are
valued
at
the
last
sales
price
on
the
day
of
valuation
on
the
securities
exchange
or
national
securities
market
on
which
such
securities
primarily
are
traded.
Securities
listed
on
the
National
Association
of
Securities
Dealers
Automated
Quotation
System
(“NASDAQ”)
for
which
market
quotations
are
available
will
be
valued
at
the
official
closing
price.
If
there
are
no
transactions
in
a
security,
or
no
official
closing
prices
for
a
NASDAQ
market-listed
security
on
that
day,
the
security
will
be
valued
at
the
average
of
the
most
recent
bid
and
asked
prices.
Bid
price
is
used
when
no
asked
price
is
available.
Open
short
positions
for
which
there
is
no
sale
price
on
a
given
day
are
valued
at
the
lowest
asked
price.
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value.
All
of
the
preceding
securities
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
The
table
below
summarizes
the
inputs
used
as
of August
31,
2024
in
valuing
the
fund’s
investments:
Fair
Value
Measurements
(b)
Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
Pursuant
to
a
securities
lending
agreement
with
BNY,
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
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
ended
August
31,
2024,
BNY
earned
$132 from
the
lending
of
the
fund’s portfolio
securities,
pursuant
to
the
securities
lending
agreement.
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
14,626,683
—
—
14,626,683
Investment
Companies
81,938
—
—
81,938
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
11
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
August
31,
2024,
the
fund
had
securities
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
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.
Fluctuation
of
Net
Asset
Value,
Share
Premiums
and
Discounts
Risk:
As
with
all
exchange-traded
funds,
fund
shares
may
be
bought
and
sold
in
the
secondary
market
at
market
prices. The
trading
prices
of
fund
shares
in
the
secondary
market
may
differ
from
the
fund's
daily
net
asset
value
per
share
and
there
may
be
times
when
the
market
price
of
the
shares
is
more
than
the
net
asset
value
per
share
(premium)
or
less
than
the
net
asset
value
per
share
(discount). This
risk
is
heightened
in
times
of
market
volatility
or
periods
of
steep
market
declines.
Non-Diversification
Risk:
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.
(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.
Assets
($)
Liabilities
($)
Securities
Lending
877,528
—
Total
gross
amount
of
assets
and
liabilities
in
the
Statement
of
Assets
and
Liabilities
877,528
—
Collateral
(received)/posted
not
offset
in
the
Statement
of
Assets
and
Liabilities
(877,528)
†
—
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.
12
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
(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 August
31,
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 August
31,
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.
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
fund
has
an
unused
capital
loss
carryover
of
$20,599
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
February
29,
2024.
These
short-term
capital
losses
can
be
carried
forward
for
an
unlimited
period.
The
fund
had
no
distributions
paid
to
shareholders
during
the
fiscal
year
ended
February
29,
2024.
The
tax
character
of
current
year
distributions
will
be
determined
at
the
end
of
the
current
fiscal
year.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.50%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expenses,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
August
31,
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
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
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 $6,132.
(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.
13
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions,
if
any,
during
the
period
ended
August
31,
2024, amounted
to $3,807,815
and
$3,681,686,
respectively.
At August
31,
2024,
accumulated
net
unrealized
appreciation on
investments
was
$3,056,564,
consisting
of
gross
appreciation
of
$4,319,363
and
gross
depreciation
of
$1,262,799.
At
August
31,
2024,
the
cost
of
investments
for
federal
income
tax
purposes
was
substantially
the
same
as
the
cost
for
financial
reporting
purposes
(see
the
Statement
of
Investments).
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
in-kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
Seed
Capital:
As
of
August
31,
2024,
MBC
Investments
Corporation,
a
wholly-owned
subsidiary
of
BNY,
held
379,401
shares
of
the
fund.
In-kind
Redemptions:
For
financial
reporting
purposes,
in-kind
redemptions
are
treated
as
sales
of
securities
resulting
in
realized
capital
gains
or
losses
to
the
fund.
Because
such
gains
or
losses
are
not
taxable
to
the
fund
and
are
not
distributed
to
existing
fund
shareholders,
the
gains
or
losses
are
reclassified
from
accumulated
net
realized
gain
(loss)
to
paid-in
capital
at
the
end
of
the
fund’s
tax
year.
These
reclassifications
have
no
effect
on
net
assets
or
net
asset
value
per
share.
During
the
period
ended
August
31,
2024,
the
fund
had
no
in-
kind
transactions.
14
Item
8.
Changes
in
and
Disagreements
with
Accountants
for
Open-End
Management
Investment
Companies
(Unaudited)
N/A
15
Item
9.
Proxy
Disclosures
for
Open-End
Management
Investment
Companies
(Unaudited)
N/A
16
Item
10.
Remuneration
Paid
to
Directors,
Officers,
and
Others
of
Open-End
Investment
Companies
(Unaudited)
Each
member
of
the
Board
serves
as
a
Board
member
of
each
fund
within
the
Registrant.
The
Board
members
are
not
compensated
directly
by
the
Registrant.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Registrant.
17
Item
11.
Statement
Regarding
Basis
for
Approval
of
Investment
Advisory
Contracts
(Unaudited)
At
a
meeting
held
on
May
7,
2024,
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended,
evaluated
proposals:
(i)
to
continue
the
management
agreement
(the
“Management
Agreement”)
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”)
with
respect
to
the
BNY
Mellon
Innovators
ETF
(the
“fund”);
(ii)
to
continue
the
sub-investment
advisory
agreement
(the
“Sub-Investment
Advisory
Agreement”)
between
the
Adviser
and
Newton
Investment
Management
North
America,
LLC
(the
“Sub-Adviser”),
an
affiliate
of
the
Adviser,
on
behalf
of
the
fund;
and
(iii)
to
continue
the
sub-sub-investment
advisory
agreement
(the
“SSIA
Agreement”)
between
the
Sub-Adviser
and
Newton
Investment
Management
Limited
(“NIM”),
also
an
affiliate
of
the
Adviser,
on
behalf
of
the
fund,
which
permits
the
Sub-Adviser
to
use
the
investment
advisory
personnel,
resources
and
capabilities
(“Investment
Advisory
Services”)
available
at
its
sister
company,
NIM,
in
providing
the
day-to-day
management
of
the
fund’s
investments.
The
Management
Agreement,
the
Sub-
Advisory
Agreement
and
the
SSIA
Agreement
are
each
referred
to
herein
as
an
“Agreement”
and
collectively,
as
the
“Agreements”.
The
Trustees
met
separately
to
consider
the
Agreements
and
were
advised
by
legal
counsel
throughout
the
process.
To
evaluate
the
Agreements,
the
Board
requested,
and
the
Adviser,
Sub-Adviser
and
NIM
provided,
such
materials
as
the
Board,
with
the
advice
of
counsel,
deemed
reasonably
necessary.
In
addition,
the
Board
considered
information
it
reviewed
at
other
Board
and
Board
committee
meetings.
In
deciding
whether
to
approve
the
Agreements,
the
Board
considered
various
factors,
including
the
(i)
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
Sub-Adviser
under
each
respective
Agreement,
(ii)
nature,
extent
and
quality
of
services
expected
to
be
provided
by
NIM
under
the
SSIA
Agreement,
(iii)
investment
performance
of
the
fund,
(iv)
profits
realized
by
the
Adviser
and
its
affiliates
from
its
relationship
with
the
fund,
(v)
fees
charged
to
comparable
funds,
(vi)
other
benefits
to
the
Adviser,
Sub-Adviser,
NIM
and/or
their
affiliates,
and
(vii)
extent
to
which
economies
of
scale
would
be
shared
as
the
fund
grows.
The
Board
considered
the
Agreements
for
the
fund
and
the
engagement
of
the
Adviser,
Sub-Adviser
and
NIM
separately.
The
Board
reviewed
reports
prepared
by
Broadridge
Financial
Solutions,
Inc.
(“Broadridge”),
an
independent
provider
of
investment
company
data,
which
included
information
(i)
comparing
the
fund’s
performance
with
the
performance
of
a
group
of
other
mid-cap
growth
exchange-traded
funds
(“ETFs”)
(the
“Performance
Group”)
and
with
a
broader
group
of
retail
and
institutional
mid-cap
growth
funds
and
ETFs
(the
“Performance
Universe”)
for
the
three-month,
six-month
and
nine-month
periods
ended
March
31,
2024;
and
(ii)
comparing
the
fund’s
contractual
management
fees
and
total
expenses
with
a
group
of
other
mid-cap
growth
ETFs
(the
“Expense
Group”)
and,
with
respect
to
total
expenses,
with
a
broader
group
of
mid-cap
growth
ETFs
(the
“Expense
Universe”),
the
information
for
which
was
derived
in
part
from
fund
financial
statements
available
to
Broadridge
as
of
the
date
of
its
analysis.
Nature,
Extent
and
Quality
of
Services
The
Board
considered
the
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
the
Sub-Adviser,
as
well
as
the
nature,
extent
and
quality
of
services
expected
to
be
provided
by
NIM.
In
doing
so,
the
Board
relied
on
its
prior
experience
in
overseeing
the
management
of
the
fund
and
the
materials
provided
prior
to
and
at
the
meeting.
The
Board
reviewed
the
Agreements
and
the
Adviser’s
and
Sub-Adviser’s
responsibilities
for
managing
investment
operations
of
the
fund
in
accordance
with
the
fund’s
investment
objective
and
policies,
and
applicable
legal
and
regulatory
requirements.
The
Board
appreciated
the
nature
of
the
fund
as
an
exchange-traded
fund
and
considered
the
background
and
experience
of
the
Adviser’s,
Sub-Adviser’s
and
NIM’s
senior
management,
including
those
individuals
responsible
for
portfolio
management
and
regulatory
compliance
of
the
fund.
The
Board
also
considered
the
portfolio
management
resources,
structures
and
practices
of
the
Adviser,
Sub-Adviser
and
NIM,
including
those
associated
with
monitoring
and
ensuring
the
fund’s
compliance
with
its
investment
objective
and
policies
and
with
applicable
laws
and
regulations.
The
Board
further
considered
information
about
the
Sub-Adviser’s
and
NIM’s
best
execution
procedures
as
well
as
the
Adviser’s,
Sub-Adviser’s
and
NIM’s
overall
investment
management
business.
The
Board
looked
at
the
Adviser’s
general
knowledge
of
the
investment
management
business
and
that
of
its
affiliates,
including
the
Sub-Adviser
and
NIM.
With
respect
to
the
Sub-Adviser,
the
Board
also
considered
the
Adviser’s
favorable
assessment
of
the
nature
and
quality
of
the
services
provided
by
the
Sub-Adviser.
With
respect
to
NIM,
the
Board
also
considered
the
Adviser’s
favorable
assessment
of
the
nature
and
quality
of
services
expected
to
be
provided
by
NIM.
Investment
Performance
The
Board
then
reviewed
the
results
of
the
fund’s
performance
comparisons
and
considered
that
the
fund’s
total
return
performance
was
below
the
Performance
Group
median
for
the
three-month,
six-month
and
nine-month
periods
ended
March
31,
2024,
below
the
Performance
Universe
median
and
benchmark
for
the
three-month
and
nine-month
periods
ended
March
31,
2024,
and
above
the
Performance
Universe
median
and
benchmark
for
the
six-month
period
ended
March
31,
2024.
Representatives
of
the
Adviser
indicated
that
the
usefulness
of
performance
comparisons
may
be
affected
by
a
number
of
factors,
including
different
investment
limitations
and
policies
that
may
be
applicable
to
the
fund
and
comparison
funds
and
the
end
date
selected.
The
representatives
noted
the
limited
time
period
of
the
performance
information,
and
further
noted
that
the
fund
had
outperformed
the
largest
thematic
fund
included
the
Performance
Group
for
the
six-month
and
nine-month
periods
ended
March
31,
2024.
18
Item
11.
Statement
Regarding
Basis
for
Approval
of
Investment
Advisory
Contracts
(Unaudited)
(continued)
Profits
Realized
by
the
Adviser
The
Board
considered
the
profitability
of
the
advisory
arrangement
with
the
fund
to
the
Adviser
and
its
affiliates.
The
Board
had
the
opportunity
to
discuss
with
representatives
of
the
Adviser
the
process
and
methodology
used
to
calculate
profitability.
Fees
Charged
to
Comparable
Funds
The
Board
evaluated
the
fund’s
unitary
fee
through
review
of
comparative
information
with
respect
to
fees
paid
by
similar
funds
(i.e.,
other
mid-cap
growth
ETFs).
The
Board
explored
with
management
the
differences
between
the
fund’s
fee
and
fees
paid
by
similar
funds.
The
Board
noted
the
fund’s
contractual
management
fee
was
less
than
the
Expense
Group
median
and
the
fund’s
total
expenses
were
less
than
the
Expense
Group
median
and
Expense
Universe
median
total
expenses.
The
Board
considered
the
fee
paid
to
the
Sub-Adviser
in
relation
to
the
fee
paid
to
the
Adviser
by
the
fund
and
the
respective
services
provided
by
the
Sub-Adviser
and
the
Adviser.
The
Board
also
took
into
consideration
that
the
Sub-Adviser’s
fee
is
paid
by
the
Adviser
and
not
the
fund.
Furthermore,
the
Board
noted
NIM
would
not
receive
a
fee
in
connection
with
providing
the
Investment
Advisory
Services.
Other
Benefits
The
Board
also
considered
whether
the
Adviser,
Sub-Adviser,
NIM
or
their
affiliates
benefited
in
other
ways
from
their
relationship
with
the
fund,
including
any
soft-dollar
arrangements
in
connection
with
the
fund’s
brokerage
transactions.
The
Board
noted
The
Bank
of
New
York
Mellon
Corporation
may
derive
certain
benefits
from
an
incremental
growth
in
its
businesses
that
may
possibly
result
from
the
availability
of
the
fund
to
clients.
Economies
of
Scale
The
Board
reviewed
information
regarding
economies
of
scale
or
other
efficiencies
that
may
result
as
the
fund’s
assets
grow
in
size.
The
Board
noted
that
the
advisory
fee
rate
for
the
fund
did
not
provide
for
breakpoints
as
assets
of
the
fund
increase.
The
Adviser
asserted
that
one
of
the
benefits
of
the
unitary
fee
was
to
provide
an
unvarying
expense
structure,
which
could
be
lost
or
diluted
with
the
addition
of
breakpoints.
The
Board
noted
that
it
intends
to
continue
to
monitor
fees
as
the
fund
grows
in
size
and
assess
whether
fee
breakpoints
may
be
warranted.
Conclusion
After
weighing
the
foregoing
factors,
none
of
which
was
dispositive
in
itself
and
may
have
been
weighed
differently
by
each
Trustee,
the
Board
approved
the
continuation
of
the
Agreements
for
the
fund.
In
approving
the
continuance
of
the
Agreements,
the
Board
found
that
the
terms
of
the
Agreements
are
fair
and
reasonable,
and
that
the
continuance
of
the
Agreements
is
in
the
best
interests
of
the
fund
and
its
shareholders.
©
2024
BNY
Mellon
Securities
Corporation
Code-4867NCSRSA0824
BNY
Mellon
ETF
Trust
SEMI-ANNUAL
FINANCIALS
AND
OTHER
INFORMATION
August
31,
2024
BNY
Mellon
Women’s
Opportunities
ETF:
BKWO
Principal
U.S.
Listing
Exchange:
The
NASDAQ
Stock
Market
LLC
IMPORTANT
NOTICE
–
CHANGES
TO
ANNUAL
AND
SEMI-ANNUAL
REPORTS
The
Securities
and
Exchange
Commission
(the
“SEC”)
has
adopted
rule
and
form
amendments
which
have
resulted
in
changes
to
the
design
and
delivery
of
annual
and
semi-annual
fund
reports
(“Reports”).
Reports
are
now
streamlined
to
highlight
key
information.
Certain
information
previously
included
in
Reports,
including
financial
statements,
no
longer
appear
in
the
Reports
but
will
be
available
online
within
the
Semi-Annual
and
Annual
Financials
and
Other
Information,
delivered
free
of
charge
to
shareholders
upon
request,
and
filed
with
the
SEC.
Contents
The
Fund
Please
note
the
Semi-Annual
Financials
and
Other
Information
only
contains
Items
7-11
required
in
Form
N-CSR.
All
other
required
items
will
be
filed
with
the
SEC.
Item
7.
Financial
Statements
and
Financial
Highlights
for
Open-End
Management
Investment
Companies
3
Statement
of
Investments
3
Statement
of
Assets
and
Liabilities
6
Statement
of
Operations
7
Statement
of
Changes
in
Net
Assets
8
Financial
Highlights
9
Notes
to
Financial
Statements
10
Item
8.
Changes
in
and
Disagreements
with
Accountants
for
Open-End
Management
Investment
Companies
15
Item
9.
Proxy
Disclosures
for
Open-End
Management
Investment
Companies
16
Item
10.
Remuneration
Paid
to
Directors,
Officers,
and
Others
of
Open-End
Investment
Companies
17
Item
11.
Statement
Regarding
Basis
for
Approval
of
Investment
Advisory
Contracts
18
Save
time.
Save
paper.
View
your
next
shareholder
report
online
as
soon
as
it’s
available.
Log
into
www.bny.com/investments
and
sign
up
for
eCommunications.
It’s
simple
and
only
takes
a
few
minutes.
The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
•
Not
Bank-Guaranteed
•
May
Lose
Value
3
BNY
Mellon
Women’s
Opportunities
ETF
Statement
of
Investments
August
31,
2024
(Unaudited)
Item
7.
Financial
Statements
and
Financial
Highlights
for
Open-End
Management
Investment
Companies
Description
Shares
Value
($)
Common
Stocks
–
98.9%
Banks
–
6.4%
Bank
of
America
Corp.
5,483
223,432
First
Horizon
Corp.
7,739
128,390
JPMorgan
Chase
&
Co.
2,252
506,250
858,072
Capital
Goods
–
4.8%
Eaton
Corp.
PLC
655
201,039
nVent
Electric
PLC
1,935
131,503
Trane
Technologies
PLC
848
306,688
639,230
Commercial
&
Professional
Services
–
0.9%
Veralto
Corp.
1,031
115,915
Consumer
Discretionary
Distribution
&
Retail
–
7.0%
Amazon.com,
Inc.
(a)
4,280
763,980
Best
Buy
Co.,
Inc.
1,783
179,013
942,993
Consumer
Services
–
2.3%
Bright
Horizons
Family
Solutions,
Inc.
(a)
2,156
303,392
Energy
–
3.1%
ConocoPhillips
1,012
115,155
Occidental
Petroleum
Corp.
2,773
158,006
Schlumberger
NV
3,384
148,862
422,023
Financial
Services
–
2.8%
Mastercard,
Inc.,
Class
A
784
378,939
Food,
Beverage
&
Tobacco
–
1.8%
Coca-Cola
Co.
(The)
3,287
238,209
Health
Care
Equipment
&
Services
–
7.9%
Addus
HomeCare
Corp.
(a)
1,152
153,227
Boston
Scientific
Corp.
(a)
3,665
299,760
Centene
Corp.
(a)
2,400
189,192
Cooper
Cos.,
Inc.
(The)
(a)
1,652
174,666
Hologic,
Inc.
(a)
1,816
147,532
Intuitive
Surgical,
Inc.
(a)
212
104,438
1,068,815
Household
&
Personal
Products
–
2.0%
Procter
&
Gamble
Co.
(The)
1,558
267,259
Insurance
–
2.1%
Progressive
Corp.
(The)
1,103
278,177
Materials
–
0.7%
Constellium
SE
(a)
5,856
98,205
Media
&
Entertainment
–
5.0%
Meta
Platforms,
Inc.,
Class
A
887
462,402
Pinterest,
Inc.,
Class
A
(a)
3,204
102,656
Walt
Disney
Co.
(The)
1,248
112,794
677,852
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
11.0%
AbbVie,
Inc.
2,158
423,637
Alnylam
Pharmaceuticals,
Inc.
(a)
480
126,091
4
Statement
of
Investments
(continued)
Description
Shares
Value
($)
Common
Stocks
–
98.9%
(continued)
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
11.0%
(continued)
Avantor,
Inc.
(a)
5,402
139,588
Eli
Lilly
&
Co.
410
393,608
Illumina,
Inc.
(a)
989
129,954
Natera,
Inc.
(a)
668
78,998
Zoetis,
Inc.,
Class
A
1,043
191,380
1,483,256
Real
Estate
Management
&
Development
–
1.0%
CoStar
Group,
Inc.
(a)
1,779
137,517
Semiconductors
&
Semiconductor
Equipment
–
10.2%
Micron
Technology,
Inc.
1,757
169,094
NVIDIA
Corp.
8,760
1,045,681
Texas
Instruments,
Inc.
756
162,041
1,376,816
Software
&
Services
–
18.7%
Accenture
PLC,
Class
A
761
260,224
Akamai
Technologies,
Inc.
(a)
1,517
154,491
HubSpot,
Inc.
(a)
476
237,557
Intuit,
Inc.
496
312,609
Microsoft
Corp.
2,646
1,103,753
Shopify,
Inc.,
Class
A
(a)
4,488
332,426
Workday,
Inc.,
Class
A
(a)
405
106,592
2,507,652
Technology
Hardware
&
Equipment
–
5.1%
Apple,
Inc.
2,976
681,504
Transportation
–
4.4%
FedEx
Corp.
655
195,694
Uber
Technologies,
Inc.
(a)
5,337
390,295
585,989
Utilities
–
1.7%
Dominion
Energy,
Inc.
4,163
232,712
Total
Common
Stocks
(cost
$9,870,716)
13,294,527
Investment
Companies
–
1.1%
Registered
Investment
Companies
–
1.1%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.27%
(b)(c)
(cost
$148,416)
148,416
148,416
Total
Investments
(cost
$10,019,132)
100.0%
13,442,943
Cash
and
Receivables
(Net)
0.0%
1,603
Net
Assets
100.0%
13,444,546
(a)
Non-income
producing
security.
(b)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(c)
The
rate
shown
is
the
1-day
yield
as
of
August
31,
2024.
5
See
Notes
to
Statement
of
Investments
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
August
31,
2024
are
as
follows:
Description
Value
($)
2/29/24
Purchases
($)
1
Sales
($)
Value
($)
8/31/24
Dividends/
Distributions
($)
Investment
Companies
–
1.1%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
107,148
120,803
(79,535)
148,416
3,536
Investment
of
Cash
Collateral
for
Securities
Loaned
–
0.0%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
—
2,552
(2,552)
—
19
2
Total
–
1.1%
107,148
123,355
(82,087)
148,416
3,555
1
Includes
reinvested
dividends/distributions.
2
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.
6
STATEMENT
OF
ASSETS
AND
LIABILITIES
August
31,
2024
(Unaudited)
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
–
Unaffiliated
issuers
9,870,716
13,294,527
Affiliated
issuers
148,416
148,416
Dividends
receivable
7,112
13,450,055
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—Note
3(b)
5,509
5,509
Net
Assets
($)
13,444,546
Composition
of
Net
Assets
($):
Paid-in
capital
10,000,029
Total
distributable
earnings
(loss)
3,444,517
Net
Assets
($)
13,444,546
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
400,001
Net
asset
value
per
share
33.61
Market
price
per
share
33.62
7
STATEMENT
OF
OPERATIONS
Six
Months
Ended
August
31,
2024
(Unaudited)
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Unaffiliated
issuers
48,937
Affiliated
issuers
3,536
Income
from
securities
lending—Note
2(b
)
19
Total
Income
52,492
Expenses:
Management
fee—Note
3(a)
32,402
Total
Expenses
32,402
Net
Investment
Income
20,090
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
58,689
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
763,012
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
821,701
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
841,791
8
STATEMENT
OF
CHANGES
IN
NET
ASSETS
See
Notes
to
Financial
Statements
Six
Months
Ended
August
31,
2024
(Unaudited)
For
the
Period
from
May
18,
2023
(a)
to
February
29,
2024
Operations
($):
Net
investment
income
20,090
42,506
Net
realized
gain
(loss)
on
investments
58,689
(70,123)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
763,012
2,660,799
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
841,791
2,633,182
Distributions
to
shareholders
—
(30,456)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
—
10,000,025
Transaction
fees—Note
5
—
4
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
—
10,000,029
Total
Increase
(Decrease)
in
Net
Assets
841,791
12,602,755
Net
Assets
($):
Beginning
of
Period
12,602,755
—
End
of
Period
13,444,546
12,602,755
Changes
in
Shares
Outstanding:
Shares
sold
—
400,001
Net
Increase
(Decrease)
in
Shares
Outstanding
—
400,001
(a)
Commencement
of
operations.
9
FINANCIAL
HIGHLIGHTS
See
Notes
to
Financial
Statements
Six
Months
Ended
August
31,
2024
(Unaudited)
For
the
Period
from
May
18,
2023
(a)
to
February
29,
2024
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
31.51
25.00
Investment
Operations:
Net
investment
income
(b)
0.05
0.11
Net
realized
and
unrealized
gain
(loss)
on
investments
2.05
6.48
Total
from
Investment
Operations
2.10
6.59
Dividends
from
net
investment
income
—
(0.08)
Transaction
fees
(b)
—
0.00
(c)
Net
asset
value,
end
of
period
33.61
31.51
Market
price,
end
of
period
33.62
31.55
Net
Asset
Value
Total
Return
(%)
(d)
6.68
26.36
(e)
Market
Price
Total
Return
(%)
(d)
6.56
26.53
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.50
(f)
0.50
(f)
Ratio
of
net
investment
income
to
average
net
assets
0.31
(f)
0.50
(f)
Portfolio
Turnover
Rate
(g)
19.07
24.71
Net
Assets,
end
of
period
($
x
1,000)
13,445
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.
10
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
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
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”),
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
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-adviser.
NIMNA
has
entered
into
a
sub-sub-investment
advisory
agreement
with
its
affiliate,
Newton
Investment
Management
Limited
(“NIM”),
which
enables
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
NIMNA
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.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“Fund
Shares.”
Fund
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).
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
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.
11
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
equity
securities,
including
ETFs
(but
not
including
investments
in
other
open-end
registered
investment
companies),
generally
are
valued
at
the
last
sales
price
on
the
day
of
valuation
on
the
securities
exchange
or
national
securities
market
on
which
such
securities
primarily
are
traded.
Securities
listed
on
the
National
Association
of
Securities
Dealers
Automated
Quotation
System
(“NASDAQ”)
for
which
market
quotations
are
available
will
be
valued
at
the
official
closing
price.
If
there
are
no
transactions
in
a
security,
or
no
official
closing
prices
for
a
NASDAQ
market-listed
security
on
that
day,
the
security
will
be
valued
at
the
average
of
the
most
recent
bid
and
asked
prices.
Bid
price
is
used
when
no
asked
price
is
available.
Open
short
positions
for
which
there
is
no
sale
price
on
a
given
day
are
valued
at
the
lowest
asked
price.
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value.
All
of
the
preceding
securities
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy.
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
The
table
below
summarizes
the
inputs
used
as
of August
31,
2024
in
valuing
the
fund’s
investments:
Fair
Value
Measurements
(b) Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
Pursuant
to
a
securities
lending
agreement
with
BNY,
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
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
ended
August
31,
2024,
BNY
earned
$3 from
the
lending
of
the
fund’s portfolio
securities,
pursuant
to
the
securities
lending
agreement.
For
financial
reporting
purposes,
the
fund
elects
not
to
offset
assets
and
liabilities
subject
to
a
securities
lending
agreement,
if
any,
in
the
Statement
of
Assets
and
Liabilities.
Therefore,
all
qualifying
transactions
are
presented
on
a
gross
basis
in
the
Statement
of
Assets
and
Liabilities.
As
of
August
31,
2024,
the
fund
had
no
securities
lending.
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
13,294,527
—
—
13,294,527
Investment
Companies
148,416
—
—
148,416
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
12
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
(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.
Investment
Theme Risk:
The
fund’s
incorporation
of
Women’s
Opportunities
considerations
into
its
investment
approach
may
cause
the
fund
to
make
different
investments
than
funds
that
invest
principally
in
equity
securities
but
do
not
incorporate
Women’s
Opportunities
considerations
when
selecting
investments.
Under
certain
economic
conditions,
this
could
cause
the
fund
to
underperform
funds
that
do
not
incorporate
Women’s
Opportunities
considerations.
For
example,
the
incorporation
of
Women’s
Opportunities
considerations
may
result
in
the
fund
forgoing
opportunities
to
buy
certain
securities
when
it
might
otherwise
be
advantageous
to
do
so
or
selling
securities
when
it
might
otherwise
be
disadvantageous
for
the
fund
to
do
so.
The
incorporation
of
Women’s
Opportunities
considerations
may
also
affect
the
fund’s
exposure
to
certain
sectors
and/or
types
of
investments
and
may
adversely
impact
the
fund’s
performance
depending
on
whether
such
sectors
or
investments
are
in
or
out
of
favor
in
the
market.
NIMNA’s
security
selection
process
incorporates
Women’s
Opportunities
data
provided
by
third
parties,
which
may
be
limited
for
certain
issuers
and/or
only
take
into
account
one
or
a
few
Women’s
Opportunities
related
components.
In
addition,
Women’s
Opportunities
data
may
include
quantitative
and/or
qualitative
measures,
and
consideration
of
this
data
may
be
subjective.
Different
methodologies
may
be
used
by
the
various
data
sources
that
provide
Women’s
Opportunities
data.
Women’s
Opportunities
data
from
third
parties
used
by
NIMNA
as
part
of
its
process
often
lacks
standardization,
consistency
and
transparency,
and
for
certain
issuers
such
data
may
not
be
available
complete
or
accurate.
NIMNA’s
evaluation
of
Women’s
Opportunities
factors
relevant
to
a
particular
issuer
may
be
adversely
affected
in
such
instances.
As
a
result,
the
fund’s
investments
may
differ
from,
and
potentially
underperform,
funds
that
incorporate
Women’s
Opportunities
data
from
other
sources
or
utilize
other
methodologies.
Authorized
Participants,
Market
Makers
and
Liquidity
Providers Risk:
The
fund
has
a
limited
number
of
financial
institutions
that
may
act
as
Authorized
Participants,
which
are
responsible
for
the
creation
and
redemption
activity
for
the
fund.
In
addition,
there
may
be
a
limited
number
of
market
makers
and/or
liquidity
providers
in
the
marketplace.
To
the
extent
either
of
the
following
events
occur,
fund
shares
may
trade
at
a
material
discount
to
net
asset
value
and
possibly
face
delisting:
(i)
Authorized
Participants
exit
the
business
or
otherwise
become
unable
to
process
creation
and/or
redemption
orders
and
no
other
Authorized
Participants
step
forward
to
perform
these
services,
or
(ii)
market
makers
and/or
liquidity
providers
exit
the
business
or
significantly
reduce
their
business
activities
and
no
other
entities
step
forward
to
perform
their
functions.
Fluctuation
of
Net
Asset
Value,
Share
Premiums
and
Discounts
Risk:
As
will
all
exchange-traded
funds,
fund
shares
may
be
bought
and
sold
in
the
secondary
market
at
market
prices.
The
trading
prices
of
fund
shares
in
the
secondary
market
may
differ
from
the
fund’s
daily
net
asset
value
per
share
and
there
may
be
times
when
the
market
price
of
the
shares
is
more
than
the
net
asset
value
per
share
(premium)
or
less
than
the
net
asset
value
per
share
(discount).
This
risk
is
heightened
in
times
of
market
volatility
or
periods
of
steep
market
declines.
Non-Diversification
Risk:
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.
(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.
13
As
of
and
during
the period
ended August
31,
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 August
31,
2024,
the
fund
did
not
incur
any
interest
or
penalties.
The
tax
year ended February
29,
2024
remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities.
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
fund
has
an
unused
capital
loss
carryover
of
$69,408
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
February
29,
2024.
These
short-term
capital
losses
can
be
carried
forward
for
an
unlimited
period.
The
tax
character
of
distributions
paid
to
shareholders
during
the
fiscal
year
ended
February
29,
2024
were
as
follows:
ordinary
income
$30,456.
The
tax
character
of
current
year
distributions
will
be
determined
at
the
end
of
the
current
fiscal
year.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.50%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expenses,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
August
31,
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
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
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 $5,509.
(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,
if
any,
during
the
period
ended
August
31,
2024, amounted
to $2,426,779
and
$2,444,424,
respectively.
14
NOTES
TO
FINANCIAL
STATEMENTS
(Unaudited)
(continued)
At August
31,
2024,
accumulated
net
unrealized
appreciation on
investments
was
$3,423,811,
consisting
of
gross
appreciation
of
$3,553,289
and
gross
depreciation
of
$129,478.
At
August
31,
2024,
the
cost
of
investments
for
federal
income
tax
purposes
was
substantially
the
same
as
the
cost
for
financial
reporting
purposes
(see
the
Statement
of
Investments).
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
in-kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
Seed
Capital:
As
of
August
31,
2024,
MBC
Investments
Corporation,
a
wholly-owned
subsidiary
of
BNY,
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
August
31,
2024,
the
fund
had
no
in-
kind
transactions.
15
Item
8.
Changes
in
and
Disagreements
with
Accountants
for
Open-End
Management
Investment
Companies
(Unaudited)
N/A
16
Item
9.
Proxy
Disclosures
for
Open-End
Management
Investment
Companies
(Unaudited)
N/A
17
Item
10.
Remuneration
Paid
to
Directors,
Officers,
and
Others
of
Open-End
Investment
Companies
(Unaudited)
Each
member
of
the
Board
serves
as
a
Board
member
of
each
fund
within
the
Registrant.
The
Board
members
are
not
compensated
directly
by
the
Registrant.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Registrant.
18
Item
11.
Statement
Regarding
Basis
for
Approval
of
Investment
Advisory
Contracts
(Unaudited)
At
a
meeting
held
on
May
7,
2024,
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended,
evaluated
proposals:
(i)
to
continue
the
management
agreement
(the
“Management
Agreement”)
between
the
Trust
and
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”)
with
respect
to
the
BNY
Mellon
Women’s
Opportunities
ETF
(the
“fund”);
(ii)
to
continue
the
sub-investment
advisory
agreement
(the
“Sub-
Investment
Advisory
Agreement”)
between
the
Adviser
and
Newton
Investment
Management
North
America,
LLC
(the
“Sub-Adviser”),
an
affiliate
of
the
Adviser,
on
behalf
of
the
fund;
and
(iii)
to
continue
the
sub-sub-investment
advisory
agreement
(the
“SSIA
Agreement”)
between
the
Sub-Adviser
and
Newton
Investment
Management
Limited
(“NIM”),
also
an
affiliate
of
the
Adviser,
on
behalf
of
the
fund,
which
permits
the
Sub-Adviser
to
use
the
investment
advisory
personnel,
resources
and
capabilities
(“Investment
Advisory
Services”)
available
at
its
sister
company,
NIM,
in
providing
the
day-to-day
management
of
the
fund’s
investments.
The
Management
Agreement,
the
Sub-Advisory
Agreement
and
the
SSIA
Agreement
are
each
referred
to
herein
as
an
“Agreement”
and
collectively,
as
the
“Agreements”.
The
Trustees
met
separately
to
consider
the
Agreements
and
were
advised
by
legal
counsel
throughout
the
process.
To
evaluate
the
Agreements,
the
Board
requested,
and
the
Adviser,
Sub-Adviser
and
NIM
provided,
such
materials
as
the
Board,
with
the
advice
of
counsel,
deemed
reasonably
necessary.
In
addition,
the
Board
considered
information
it
reviewed
at
other
Board
and
Board
committee
meetings.
In
deciding
whether
to
approve
the
Agreements,
the
Board
considered
various
factors,
including
the
(i)
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
Sub-Adviser
under
each
respective
Agreement,
(ii)
nature,
extent
and
quality
of
services
expected
to
be
provided
by
NIM
under
the
SSIA
Agreement,
(iii)
investment
performance
of
the
fund,
(iv)
profits
realized
by
the
Adviser
and
its
affiliates
from
its
relationship
with
the
fund,
(v)
fees
charged
to
comparable
funds,
(vi)
other
benefits
to
the
Adviser,
Sub-Adviser,
NIM
and/or
their
affiliates,
and
(vii)
extent
to
which
economies
of
scale
would
be
shared
as
the
fund
grows.
The
Board
considered
the
Agreements
for
the
fund
and
the
engagement
of
the
Adviser,
Sub-Adviser
and
NIM
separately.
The
Board
reviewed
reports
prepared
by
Broadridge
Financial
Solutions,
Inc.
(“Broadridge”),
an
independent
provider
of
investment
company
data,
which
included
information
(i)
comparing
the
fund’s
performance
with
the
performance
of
a
group
of
other
large
blended
exchange-traded
funds
(“ETFs”)
(the
“Performance
Group”)
and
with
a
broader
group
of
retail
and
institutional
large
blended
funds
and
ETFs
(the
“Performance
Universe”)
for
the
three-month,
six-month
and
nine-month
periods
ended
March
31,
2024;
and
(ii)
comparing
the
fund’s
contractual
management
fees
and
total
expenses
with
a
group
of
other
large
blended
ETFs
(the
“Expense
Group”)
and,
with
respect
to
total
expenses,
with
a
broader
group
of
large
blended
ETFs
(the
“Expense
Universe”),
the
information
for
which
was
derived
in
part
from
fund
financial
statements
available
to
Broadridge
as
of
the
date
of
its
analysis.
Nature,
Extent
and
Quality
of
Services
The
Board
considered
the
nature,
extent
and
quality
of
services
provided
by
the
Adviser
and
the
Sub-Adviser,
as
well
as
the
nature,
extent
and
quality
of
services
expected
to
be
provided
by
NIM.
In
doing
so,
the
Board
relied
on
its
prior
experience
in
overseeing
the
management
of
the
fund
and
the
materials
provided
prior
to
and
at
the
meeting.
The
Board
reviewed
the
Agreements
and
the
Adviser’s
and
Sub-Adviser’s
responsibilities
for
managing
investment
operations
of
the
fund
in
accordance
with
the
fund’s
investment
objective
and
policies,
and
applicable
legal
and
regulatory
requirements.
The
Board
appreciated
the
nature
of
the
fund
as
an
exchange-traded
fund
and
considered
the
background
and
experience
of
the
Adviser’s,
Sub-Adviser’s
and
NIM’s
senior
management,
including
those
individuals
responsible
for
portfolio
management
and
regulatory
compliance
of
the
fund.
The
Board
also
considered
the
portfolio
management
resources,
structures
and
practices
of
the
Adviser,
Sub-Adviser
and
NIM,
including
those
associated
with
monitoring
and
ensuring
the
fund’s
compliance
with
its
investment
objective
and
policies
and
with
applicable
laws
and
regulations.
The
Board
further
considered
information
about
the
Sub-Adviser’s
and
NIM’s
best
execution
procedures
as
well
as
the
Adviser’s,
Sub-Adviser’s
and
NIM’s
overall
investment
management
business.
The
Board
looked
at
the
Adviser’s
general
knowledge
of
the
investment
management
business
and
that
of
its
affiliates,
including
the
Sub-Adviser
and
NIM.
With
respect
to
the
Sub-Adviser,
the
Board
also
considered
the
Adviser’s
favorable
assessment
of
the
nature
and
quality
of
the
services
provided
by
the
Sub-Adviser.
With
respect
to
NIM,
the
Board
also
considered
the
Adviser’s
favorable
assessment
of
the
nature
and
quality
of
services
expected
to
be
provided
by
NIM.
Investment
Performance
The
Board
then
reviewed
the
results
of
the
fund’s
performance
comparisons
and
considered
that
the
fund’s
total
return
performance
was
above
the
Performance
Group
and
Performance
Universe
medians
and
above
its
benchmark
for
the
three-month,
six-month
and
nine-
month
periods
ended
March
31,
2024.
Representatives
of
the
Adviser
indicated
that
the
usefulness
of
performance
comparisons
may
be
affected
by
a
number
of
factors,
including
different
investment
limitations
and
policies
that
may
be
applicable
to
the
fund
and
comparison
funds
and
the
end
date
selected.
Profits
Realized
by
the
Adviser
The
Board
considered
the
profitability
of
the
advisory
arrangement
with
the
fund
to
the
Adviser
and
its
affiliates.
The
Board
had
the
opportunity
to
discuss
with
representatives
of
the
Adviser
the
process
and
methodology
used
to
calculate
profitability.
19
Fees
Charged
to
Comparable
Funds
The
Board
evaluated
the
fund’s
unitary
fee
through
review
of
comparative
information
with
respect
to
fees
paid
by
similar
funds
(i.e.,
other
large
blended
ETFs).
The
Board
explored
with
management
the
differences
between
the
fund’s
fee
and
fees
paid
by
similar
funds.
The
Board
noted
the
fund’s
contractual
management
fee
was
slightly
higher
than
the
Expense
Group
median
and
the
fund’s
total
expenses
were
slightly
higher
than
the
Expense
Group
median
and
slightly
lower
than
the
Expense
Universe
median
total
expenses.
The
Board
considered
the
fee
paid
to
the
Sub-Adviser
in
relation
to
the
fee
paid
to
the
Adviser
by
the
fund
and
the
respective
services
provided
by
the
Sub-Adviser
and
the
Adviser.
The
Board
also
took
into
consideration
that
the
Sub-Adviser’s
fee
is
paid
by
the
Adviser
and
not
the
fund.
Furthermore,
the
Board
noted
NIM
would
not
receive
a
fee
in
connection
with
providing
the
Investment
Advisory
Services.
Other
Benefits
The
Board
also
considered
whether
the
Adviser,
Sub-Adviser,
NIM
or
their
affiliates
benefited
in
other
ways
from
their
relationship
with
the
fund,
including
any
soft-dollar
arrangements
in
connection
with
the
fund’s
brokerage
transactions.
The
Board
noted
The
Bank
of
New
York
Mellon
Corporation
may
derive
certain
benefits
from
an
incremental
growth
in
its
businesses
that
may
possibly
result
from
the
availability
of
the
fund
to
clients.
Economies
of
Scale
The
Board
reviewed
information
regarding
economies
of
scale
or
other
efficiencies
that
may
result
as
the
fund’s
assets
grow
in
size.
The
Board
noted
that
the
advisory
fee
rate
for
the
fund
did
not
provide
for
breakpoints
as
assets
of
the
fund
increase.
The
Adviser
asserted
that
one
of
the
benefits
of
the
unitary
fee
was
to
provide
an
unvarying
expense
structure,
which
could
be
lost
or
diluted
with
the
addition
of
breakpoints.
The
Board
noted
that
it
intends
to
continue
to
monitor
fees
as
the
fund
grows
in
size
and
assess
whether
fee
breakpoints
may
be
warranted.
Conclusion
After
weighing
the
foregoing
factors,
none
of
which
was
dispositive
in
itself
and
may
have
been
weighed
differently
by
each
Trustee,
the
Board
approved
the
continuation
of
the
Agreements
for
the
fund.
In
approving
the
continuance
of
the
Agreements,
the
Board
found
that
the
terms
of
the
Agreements
are
fair
and
reasonable,
and
that
the
continuance
of
the
Agreements
is
in
the
best
interests
of
the
fund
and
its
shareholders.
©
2024
BNY
Mellon
Securities
Corporation
Code-4868NCSRSA0824
Item 12. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.
Not applicable.
Item 13. Portfolio Managers of Closed-End Management Investment Companies.
Not applicable.
Item 14. Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.
Not applicable.
Item 15. 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 16. Controls and Procedures.
(a) The Registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the Registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”) (17 CFR 270.30a-3(c))) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act (17 CFR 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act of 1934, as amended (17 CFR 240.13a-15(b) or 240.15d-15(b)).
(b) There were no changes in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act (17 CFR 270.30a-3(d))) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.
Item 17. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.
Not applicable.
Item 18. Recovery of Erroneously Awarded Compensation.
Not Applicable.
Item 19. Exhibits.
(a)(1) Not applicable.
(a)(2) Not applicable.
(a)(3)(1) Not applicable.
(a)(3)(2) Not applicable.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
(Registrant) BNY Mellon ETF Trust
By (Signature and Title) * /s/ David J. DiPetrillo
David J. DiPetrillo, President
David J. DiPetrillo, President
(Principal Executive Officer)
Date 10/25/2024
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 10/25/2024
By (Signature and Title) * /s/ James Windels
James Windels, Treasurer
James Windels, Treasurer
(Principal Financial and Accounting Officer)
Date 10/25/2024
* Print the name and title of each signing officer under his or her signature.