Tidal ETF Trust
234 West Florida Street, Suite 203
Milwaukee, Wisconsin 53204
August 30, 2023
VIA EDGAR TRANSMISSION
Ms. Christina DiAngelo Fettig
Division of Investment Management, Disclosure Review Office
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE:
Tidal ETF Trust (the “Tidal Trust”)
Form N-14
File No. 333-273743
Dear Ms. Fettig:
This correspondence responds to a follow-up accounting-related comment the Tidal Trust received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or the “Commission”) on August 28, 2023, with respect to the Form N-14 regarding the proposed reorganization of the Gotham Short Strategies Fund (the “Target Fund”), a series of FundVantage Trust (the “FV Trust”), into the Gotham Short Strategies ETF (the “Acquiring Fund”), which is a newly created series of Tidal Trust.
Capitalized terms not otherwise defined have the same meaning as in the filing.
Regarding the Staff’s Comment 6 and the Trust’s response, the Staff notes that Item 3 of Form N-14 requires that “current fees” be disclosed. However, that term is undefined. Please confirm in correspondence that the fees presented represent current fees in accordance with Item 3 of Form N-14 (i.e., without a reference to Form N-1A).
Response: The Tidal Trust confirms that the fees presented are current in accordance with the requirements of Item 3 of Form N-14.
If you have any questions or require further information, please contact Michael Pellegrino at (844) 986-7700 #746 or mpellegrino@tidalfg.com.
Sincerely,
/s/ Michael T. Pellegrino
Michael T. Pellegrino, General Counsel
Toroso Investments, LLC
