SSPY / Exchange Listed Funds Trust - Stratified LargeCap Index ETF - SEC-Einreichungen, Jahresbericht, Proxy Statement

CERT

The Nasdaq Stock Market LLC, 1100 New York Ave. NW, Suite 310E, Washington, DC 20005 Eun Ah Choi Senior Vice President Global Head of Regulatory Operations July 22, 2025 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Division of Corporation Finance: This is to certify that on July 18, 2025 The Nasdaq Stock Market (the "Exchange") r

Securities and Exchange Commission Washington, D.C. Form 8-A For Registration of Certain Classes of Securities Pursuant to Section 12(b) or (g) of the Securities Exchange Act of 1934 WEBs ETF Trust (Exact name of registrant as specified in its charte

Securities and Exchange Commission Washington, D.C. Form 8-A For Registration of Certain Classes of Securities Pursuant to Section 12(b) or (g) of the Securities Exchange Act of 1934 WEBs ETF Trust (Exact name of registrant as specified in its charter) Delaware See Exhibit 1 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) 2497 Aspen Springs Dr, Park City, UT 84060 (Ad

WEBs ETF Trust

WEBs ETF Trust WEBs Defined Volatility SPY ETF Schedule of Investments January 31, 2025 (unaudited) SECURITY DESCRIPTION SHARES VALUE EXCHANGE-TRADED FUNDS – 51.

WEBs ETF Trust

WEBs ETF Trust WEBs Defined Volatility QQQ ETF Schedule of Investments January 31, 2025 (unaudited) SECURITY DESCRIPTION SHARES VALUE EXCHANGE-TRADED FUNDS – 52.

Securities and Exchange Commission Washington, D.C. Form 8-A For Registration of Certain Classes of Securities Pursuant to Section 12(b) or (g) of the Securities Exchange Act of 1934 WEBs ETF Trust (Exact name of registrant as specified in its charte

Securities and Exchange Commission Washington, D.C. Form 8-A For Registration of Certain Classes of Securities Pursuant to Section 12(b) or (g) of the Securities Exchange Act of 1934 WEBs ETF Trust (Exact name of registrant as specified in its charter) Delaware See Exhibit 1 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) 2497 Aspen Springs Dr, Park City, UT 84060 (Ad

June 3, 2025

Morrison Warren Partner Chapman and Cutler LLP 320 South Canal Street, 27th Floor Chicago, Illinois 60606 T (312) 845-3484 warren@chapman.

CERT

The Nasdaq Stock Market LLC, 805 King Farm Blvd., Rockville, MD 20850 Eun Ah Choi Senior Vice President Global Head of Regulatory Operations December 16, 2024 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Division of Corporation Finance: This is to certify that on December 12, 2024, The Nasdaq Stock Market LLC (the "Exchange") rec

CERT

The Nasdaq Stock Market LLC, 805 King Farm Blvd., Rockville, MD 20850 Eun Ah Choi Senior Vice President Global Head of Regulatory Operations December 16, 2024 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Division of Corporation Finance: This is to certify that on December 12, 2024, The Nasdaq Stock Market LLC (the "Exchange") rec

Securities and Exchange Commission Washington, D.C. Form 8-A For registration of certain classes of securities pursuant to section 12(b) or (g) of the securities exchange act of 1934

Securities and Exchange Commission Washington, D.C. Form 8-A For registration of certain classes of securities pursuant to section 12(b) or (g) of the securities exchange act of 1934 WEBs ETF Trust (Exact name of registrant as specified in its charter) Delaware See Exhibit 1 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) 2497 Aspen Springs Dr, Park City, UT 84060 (Ad

Securities and Exchange Commission Washington, D.C. Form 8-A For Registration of Certain Classes of Securities Pursuant to Section 12(b) or (g) of the Securities Exchange Act of 1934

Securities and Exchange Commission Washington, D.C. Form 8-A For Registration of Certain Classes of Securities Pursuant to Section 12(b) or (g) of the Securities Exchange Act of 1934 WEBs ETF Trust (Exact name of registrant as specified in its charter) Delaware See Exhibit 1 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) 2497 Aspen Springs Dr, Park City, UT 84060 (Ad

November 15, 2024

Morrison Warren Partner Chapman and Cutler llp 320 South Canal Street, 27th Floor Chicago, Illinois 60606 T (312) 845-3484 warren@chapman.

December 2, 2024

Morrison Warren Partner Chapman and Cutler LLP 320 South Canal Street, 27th Floor Chicago, Illinois 60606 T (312) 845-3484 warren@chapman.

SSLY / Syntax ETF Trust - Syntax Stratified SmallCap ETF / Vantage Consulting Group Inc Passive Investment

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 SCHEDULE 13G/A Under the Securities Exchange Act of 1934 (Amendment No.

SSLY / Syntax ETF Trust - Syntax Stratified SmallCap ETF / Vantage Consulting Group Inc Passive Investment

SC 13G/A 1 vantagesmallcap093024a2.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 SCHEDULE 13G/A Under the Securities Exchange Act of 1934 (Amendment No. 2)* Syntax ETF Trust/ Stratified Small Cap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N304 (CUSIP Number) September 30, 2024 (Date of Event Which Requires Filing of this Statement) Check the app

SSPY / Exchange Listed Funds Trust - Stratified LargeCap Index ETF / Vantage Consulting Group Inc Passive Investment

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 SCHEDULE 13G/A Under the Securities Exchange Act of 1934 (Amendment No.

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES NYSE Arca hereby notifies the SEC of its intention to remove the entire class of the stated securities from listing and registration on the Exchange at the opening of business on October 11, 2024, pursuant to the provisions of Rule 12d2-2 (a).

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES NYSE Arca hereby notifies the SEC of its intention to remove the entire class of the stated securities from listing and registration on the Exchange at the opening of business on October 11, 2024, pursuant to the provisions of Rule 12d2-2 (a).

SSPY / Syntax ETF Trust - Syntax Stratified LargeCap ETF / Vantage Consulting Group Inc Passive Investment

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 SCHEDULE 13G/A Under the Securities Exchange Act of 1934 (Amendment No.

SSLY / Syntax ETF Trust - Syntax Stratified SmallCap ETF / Vantage Consulting Group Inc Passive Investment

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 SCHEDULE 13G/A Under the Securities Exchange Act of 1934 (Amendment No.

SSPY / Syntax ETF Trust - Syntax Stratified LargeCap ETF / Vantage Consulting Group Inc Passive Investment

SC 13G/A 1 vantagelargecap083123a3.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 SCHEDULE 13G/A Under the Securities Exchange Act of 1934 (Amendment No. 3)* Syntax ETF Trust/ Stratified Large Cap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N106 (CUSIP Number) August 31, 2023 (Date of Event Which Requires Filing of this Statement) Check the approp

January 19, 2023

CORRESP 1 filename1.htm Barry Pershkow Partner Chapman and Cutler llp 1717 Rhode Island Avenue NW Washington, DC 20036-3026 Tel: 202.478.6492 Mobile: 202.276.4046 [email protected] January 19, 2023 VIA EDGAR CORRESPONDENCE Kenneth Ellington Division of Investment Management United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Syntax ETF Trust (the “Trus

SMDY / Syntax Stratified MidCap ETF / Vantage Consulting Group Inc - SYNTAX MIDCAP ETF Passive Investment

SC 13G/A 1 vtcmidcap.txt SYNTAX MIDCAP ETF SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. 5)* Syntax ETF Trust/Stratified MidCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N205 (C

2

QUARTERLY REPORT Syntax Stratified U.S. Total Market Hedged ETF March 31, 2022 Syntax Stratified U.S. Total Market Hedged ETF Schedule of Investments March 31, 2022 (Unaudited) Security Description Shares Value EXCHANGE-TRADED FUNDS?89.0% Syntax Stratified Large Cap ETF(a) 502,786 $35,144,741 Syntax Stratified MidCap ETF(a) 105,222 4,091,358 Syntax Stratified SmallCap ETF(a) 42,799 2,013,967 TOTAL

SMDY / Syntax Stratified MidCap ETF / Vantage Consulting Group Inc - SYNTAX MIDCAP ETF Passive Investment

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. 4)* Syntax ETF Trust/Stratified MidCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N205 (CUSIP Number) September 30, 2022 (Date of Ev

SMDY / Syntax Stratified MidCap ETF / Vantage Consulting Group Inc - SYNTAX MIDCAP ETF Passive Investment

SC 13G/A 1 vmidcap.txt SYNTAX MIDCAP ETF SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. 3)* Syntax ETF Trust/Stratified MidCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N205 (CUS

SMDY / Syntax Stratified MidCap ETF / Vantage Consulting Group Inc - VANTAGE 13G Passive Investment

SC 13G/A 1 Vantage.midcap.txt VANTAGE 13G SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. 2)* Syntax ETF Trust/Stratified MidCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N205 (CU

NYSE ARCA CERTIFICATION

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Syntax ETF Trust (Exact name of registrant as s

8-A12B 1 fp00769728a12b.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Syntax ETF Trust (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.R.S. Employer Identification numbe

1

June 2, 2022 Ms. Anu Dubey United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549-0102 RE: Syntax ETF Trust – SEC File Nos. 333-215607 and 811-23227 (the “Registrant”) Dear Ms. Dubey: On behalf of the Registrant, we are submitting this letter (the “Correspondence Letter”) in connection with the Registrant’s Registration Statement on

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QUARTERLY REPORT Syntax Stratified LargeCap ETF March 31, 2022 Syntax Stratified LargeCap ETF Schedule of Investments March 31, 2022 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified U.S. Total Market Hedged ETF March 31, 2022 Syntax Stratified U.S. Total Market Hedged ETF Schedule of Investments March 31, 2022 (Unaudited) Security Description Shares Value EXCHANGE-TRADED FUNDS—89.0% Syntax Stratified Large Cap ETF(a) 502,786 $35,144,741 Syntax Stratified MidCap ETF(a) 105,222 4,091,358 Syntax Stratified SmallCap ETF(a) 42,799 2,013,967 TOTAL

2

QUARTERLY REPORT Syntax Stratified SmallCap ETF March 31, 2022 Syntax Stratified SmallCap ETF Schedule of Investments March 31, 2022 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified U.S. Total Market ETF March 31, 2022 Syntax Stratified U.S. Total Market ETF Schedule of Investments March 31, 2022 (Unaudited) Security Description Shares Value EXCHANGE-TRADED FUNDS—100.0% Syntax Stratified Large Cap ETF(a) 121,432 $8,488,097 Syntax Stratified MidCap ETF(a) 25,412 988,097 Syntax Stratified SmallCap ETF(a) 10,338 486,469 TOTAL INVESTMENTS—100.0%

2

QUARTERLY REPORT Syntax Stratified MidCap ETF March 31, 2022 Syntax Stratified MidCap ETF Schedule of Investments March 31, 2022 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified SmallCap ETF September 30, 2021 Syntax Stratified SmallCap ETF Schedule of Investments September 30, 2021 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified U.S. Total Market Hedged ETF September 30, 2021 Syntax Stratified U.S. Total Market Hedged ETF Schedule of Investments September 30, 2021 (Unaudited) Security Description Shares Value EXCHANGE-TRADED FUNDS—90.2% Syntax Stratified Large Cap ETF(a) 509,196 $33,606,936 Syntax Stratified MidCap ETF(a) 101,509 3,984,980 Syntax Stratified SmallCap ETF(a) 39,038 2,027,0

2

QUARTERLY REPORT Syntax Stratified LargeCap ETF September 30, 2021 Syntax Stratified LargeCap ETF Schedule of Investments September 30, 2021 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified MidCap ETF September 30, 2021 Syntax Stratified MidCap ETF Schedule of Investments September 30, 2021 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified U.S. Total Market ETF September 30, 2021 Syntax Stratified U.S. Total Market ETF Schedule of Investments September 30, 2021 (Unaudited) Security Description Shares Value EXCHANGE-TRADED FUNDS—100.0% Syntax Stratified Large Cap ETF(a) 204,368 $13,488,288 Syntax Stratified MidCap ETF(a) 40,740 1,599,346 Syntax Stratified SmallCap ETF(a) 15,669 813,596 TOTAL INVESTM

1

CORRESP 1 filename1.htm August 11, 2021 Ms. Anu Dubey United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549-0102 RE: Syntax ETF Trust – SEC File Nos. 333-215607 and 811-23227 (the “Registrant”) Dear Ms. Dubey: On behalf of the Registrant, we are submitting this letter (the “Response Letter”) to respond to the Staff’s comments recei

SMDY / Syntax Stratified MidCap ETF / Vantage Consulting Group Inc - MIDCAP 13G Passive Investment

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. 1)* Syntax ETF Trust/Stratified MidCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N205 (CUSIP Number) June 18, 2021 (Date of Event W

SSLY / Syntax Stratified SmallCap ETF / Vantage Consulting Group Inc - SMALLCAP 13G Passive Investment

SC 13G 1 smallCap.txt SMALLCAP 13G SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. )* Syntax Straified SmallCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N304 (CUSIP Number) June

SSPY / Syntax Stratified 1000 ETF / Vantage Consulting Group Inc - STRATIFIED LARGE CAP 13G Passive Investment

SC 13G/A 1 largecap.txt STRATIFIED LARGE CAP 13G SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. 1)* Syntax ETF Trust/ Stratified Large Cap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87

1

June 23, 2021 Ms. Anu Dubey United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549-0102 RE: Syntax ETF Trust – SEC File Nos. 333-215607 and 811-23227 (the “Registrant”) Dear Ms. Dubey: In accordance with your request, I am submitting to you via EDGAR correspondence a copy of the comment response letter addressed to you dated June 11

NYSE ARCA CERTIFICATION

New York Stock Exchange 11 Wall Street New York, NY 10005 June 14, 2021 Chief, Information Technology Securities and Exchange Commission Division of Corporate Finance 100 F Street, NE MS 3040 Washington, DC 20549 To whom it may concern: The NYSE Arca certifies its approval for listing and registration of the Syntax Stratified U.

2

QUARTERLY REPORT Syntax Stratified U.S. Total Market ETF March 31, 2021 Syntax Stratified U.S. Total Market ETF Schedule of Investments March 31, 2021 (Unaudited) Security Description Shares Value EXCHANGE-TRADED FUNDS—100.0% Syntax Stratified Large Cap ETF(a) 290,270 $18,042,254 Syntax Stratified MidCap ETF(a) 53,110 2,082,619 Syntax Stratified SmallCap ETF(a) 19,890 1,030,306 TOTAL INVESTMENTS—1

2

QUARTERLY REPORT Syntax Stratified SmallCap ETF March 31, 2021 Syntax Stratified SmallCap ETF Schedule of Investments March 31, 2021 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified LargeCap ETF March 31, 2021 Syntax Stratified LargeCap ETF Schedule of Investments March 31, 2021 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified MidCap ETF March 31, 2021 Syntax Stratified MidCap ETF Schedule of Investments March 31, 2021 (Unaudited) Security Description Shares Value COMMON STOCK—99.

STRATIFIED MIDCAP ETF 13G

SC 13G 1 midcap.txt STRATIFIED MIDCAP ETF 13G SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. )* Syntax ETF Trust/Stratified MidCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 87166N205

STRATIFIED LARGECAP ETF 13G

SC 13G 1 largecap.txt STRATIFIED LARGECAP ETF 13G SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 13G (Rule 13d-102) INFORMATION TO BE INCLUDED IN STATEMENTS FILED PURSUANT TO RULE 13d-1(b), (c), AND (d) AND AMENDMENTS THERETO FILED PURSUANT TO RULE 13d-2(b) (AMENDMENT NO. )* Syntax ETF Trust/Stratified LargeCap ETF (Name of Issuer) ETF Shares (Title of Class of Securities) 8716

- NYSE ARCA CERTIFICATION

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2

QUARTERLY REPORT Syntax Stratified LargeCap ETF September 30, 2020 Syntax Stratified LargeCap ETF Schedule of Investments September 30, 2020 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified MidCap ETF September 30, 2020 Syntax Stratified MidCap ETF Schedule of Investments September 30, 2020 (Unaudited) Security Description Shares Value COMMON STOCK—99.

2

QUARTERLY REPORT Syntax Stratified SmallCap ETF September 30, 2020 Syntax Stratified SmallCap ETF Schedule of Investments September 30, 2020 (Unaudited) Security Description Shares Value COMMON STOCK—99.

- NYSE ARCA CERTIFICATION

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2

QUARTERLY REPORT Syntax Stratified LargeCap ETF March 31, 2020 Syntax Stratified LargeCap ETF Schedule of Investments March 31, 2020 (Unaudited) Security Description Shares Value COMMON STOCK—98.

2

QUARTERLY REPORT Syntax Stratified MidCap ETF March 31, 2020 Syntax Stratified MidCap ETF Schedule of Investments March 31, 2020 (Unaudited) Security Description Shares Value COMMON STOCK—99.

- 8-A12B

8-A12B 1 tm2020815-18a12b.htm 8-A12B UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Syntax ETF Trust (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.R.S. Employer Identificat

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April 15, 2020 Mr. Edward P. Bartz, Senior Counsel United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549-0102 RE: Syntax ETF Trust – SEC File Nos. 333-215607 and 811-23227 (the “Registrant”) Dear Mr. Bartz: On behalf of the Registrant, we are submitting this letter (the “Response Letter”) to respond to the Staff’s comments received

SSPY / Syntax Stratified LargeCap ETF CORRESP - -

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Syntax Etf Trust CERT - - NYSE ARCA CERTIFICATION

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Syntax Etf Trust 8-A12B - - 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Syntax ETF Trust (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.R.S. Employer Identification number) One Liberty Plaza, 46th F

Syntax Etf Trust CORRESP - -

CORRESP 1 filename1.htm 1270 Avenue of the Americas Kathleen H Moriarty 30th Floor Partner New York, New York 10020-1708 T 212.655.6000 D 212.655.2548 [email protected] January 9, 2020 VIA EDGAR CORRESPONDENCE Mr. Edward P. Bartz, Senior Counsel United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549-0102 RE: Syntax ETF Trust – SE

Syntax Etf Trust CORRESP - -

1270 Avenue of the Americas Kathleen H Moriarty 30th Floor Partner New York, New York 10020-1708 T 212.

Kathleen H Moriarty

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Kathleen H Moriarty

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Syntax Etf Trust - N-Q

N-Q 1 tm1923570-1nq.htm N-Q UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23227 Syntax ETF Trust (Exact name of registrant as specified in charter) 110 E. 59th St. 33rd Floor New York, NY 10022 (Address of principal executive offices) (Zip cod

Date: November 20, 2019

Date: November 20, 2019 I, Rory Riggs, CEO and Principal Executive Officer of the Syntax ETF Trust, certify that: 1.

Kathleen H Moriarty

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Syntax Etf Trust - N-Q

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23227 Syntax ETF Trust (Exact name of registrant as specified in charter) 110 E.

Date: May 31, 2019

Exhibit 99.CERT Date: May 31, 2019 I, Rory Riggs, CEO and Principal Executive Officer of the Syntax ETF Trust, certify that: 1. I have reviewed this report on Form N-Q of the Syntax ETF Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under whic

NYSE ARCA CERTIFICATION SYNTAX ETF TRUST

New York Stock Exchange 11 Wall Street New York, NY 10005 An Intercontinental Exchange Company © 2019 Intercontinental Exchange, Inc.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Syntax ETF Trust (Exact name of registrant as s

8-A12B 1 tv5099818a12b.htm 8-A12B UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Syntax ETF Trust (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.R.S. Employer Identification

SYNTAX ETF TRUST 110 East 59th Street, 33rd Floor New York, NY 10022

SYNTAX ETF TRUST 110 East 59th Street, 33rd Floor New York, NY 10022 November 7, 2018 VIA EDGAR Securities and Exchange Commission Washington, D.

Kathleen H Moriarty

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Consent of Independent Registered Public Accounting Firm

Exhibit (j)(i) CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm under the captions “Independent Registered Public Accounting Firm” in the Prospectus and “Counsel and Independent Registered Public Accounting Firm” in the Statement of Additional Information and to the inclusion of our report, dated October 22, 2018, on the statement of assets and liabilities of Syntax Stratified LargeCap ETF (comprising Syntax ETF Trust) as of September 30, 2018, included in Pre-Effective Amendment No.

Consent of Independent Auditors

Exhibit (j)(ii) CONSENT OF INDEPENDENT AUDITORS We consent to the references to our firm under the caption “Independent Auditors” in the Prospectus and “Independent Auditors” in the Statement of Additional Information in the Registration Statement (Form N-1A No.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

N-1A/A 1 tv505166n1aa.htm N-1A/A As filed with the Securities and Exchange Commission on October 23, 2018 1933 Act Registration No. 333-215607 1940 Act Registration No. 811-23227 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 þ Pre-Effective Amendment No. 6 þ Post-Effective Amendment No. ¨ and/or REGISTRATIO

Kathleen H Moriarty

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Opinion and consent of counsel

Exhibit (i) Kathleen H. Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, NY 10020-1708 T 212.655.2548 F 646.571.0113 [email protected] October 23, 2018 Syntax ETF Trust 110 East 59th Street, 33rd Floor New York, NY 10022 Re: Syntax ETF Trust Ladies and Gentlemen: We have acted as counsel to the Syntax ETF Trust, a Delaware statutory trust (the “Trust”), with respect to the fili

(i) Administration Agreement by and between Registrant and State Street Bank and Trust Company, is incorporated herein by reference to Exhibit (h)(i) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (h)(i) Execution copy ADMINISTRATION AGREEMENT This Administration Agreement (?Agreement?) dated and effective as of July 20, 2017, is by and between State Street Bank and Trust Company, a Massachusetts trust company (the ?Administrator?), and each of the Syntax entities listed on Schedule A attached hereto (each, a ?Trust?).

Kathleen H Moriarty

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

Code of Ethics of Foreside Fund Services, LLC

Exhibit (p)(iv) Code of Ethics Exhibit (p)(iv) Code of Ethics INTRODUCTION 1 1. STANDARDS OF PROFESSIONAL CONDUCT 2 (a) Fiduciary Duties 2 (b) Compliance with Laws 2 (c) Corporate Culture 2 (d) Professional Misconduct 3 (e) Disclosure of Conflicts 3 (f) Undue Influence 3 (g) Confidentiality and Protection of Material Nonpublic Information 3 (h) Personal Securities Transactions 4 (i) Gifts 4 (j) Se

Investment Sub-Advisory Agreement by and between Syntax Advisors, LLC and Vantage Consulting Group, is incorporated herein by reference to Exhibit (d)(ii) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (d)(ii) INVESTMENT SUB-ADVISORY AGREEMENT This Investment Sub-Advisory Agreement (this “Agreement”) is made and entered into on March 2, 2018 by and among Syntax Advisors, LLC a Limited Liability Corporation located at 110 E.

(ii) Transfer Agency and Service Agreement by and between Registrant and State Street Bank and Trust Company, is incorporated herein by reference to Exhibit (h)(ii) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (h)(ii) Execution copy TRANSFER AGENCY AND SERVICE AGREEMENT THIS AGREEMENT is made as of the 20th day of July, 2017, by and between STATE STREET BANK AND TRUST COMPANY, Massachusetts trust company having its principal office and place of business at One Lincoln Street, Boston, Massachusetts 02111 (“State Street” or the “Transfer Agent”), and each of the entities listed on Schedule A attached hereto (each, a “Trust).

ETF Distribution Agreement by and between Registrant and Foreside Fund Services, LLC, is incorporated herein by reference to Exhibit (e) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (e) ETF DISTRIBUTION AGREEMENT This Distribution Agreement (the “Agreement”) is made as of July 24, 2017, by and between Syntax ETF Trust, a Delaware statutory trust (the “Trust”) having its principal place of business at 110 East 59th Street, 31st Floor, New York, NY 10022, and Foreside Fund Services, LLC, a Delaware limited liability company (the “Distributor”) having its principal place of business at Three Canal Plaza, Suite 100, Portland, ME 04101.

(i) Investment Advisory Agreement by and between Registrant and Syntax Advisors, LLC, is incorporated herein by reference to Exhibit (d)(i) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (d)(i) INVESTMENT ADVISORY AGREEMENT This Investment Advisory Agreement (this "Agreement") is made and entered into on August 1, 2017, to be effective upon the commencement of operations of the portfolios of the Trust listed on Schedule A attached hereto, by and between - Syntax ETF Trust, a Delaware statutory trust organized on June 27, 2013 ("Trust"), and Syntax Advisors, LLC, a Limited Liability Corporation ("Advisor").

Power of Attorney

EX-99.(Q) 15 tv499452ex99-q.htm POWER OF ATTORNEY Exhibit (q) SYNTAX ETF TRUST POWER OF ATTORNEY Each of the undersigned Trustees and Officers of Syntax ETF Trust (the "Trust") hereby constitutes and appoints Kathleen Cuocolo and Carly Arison, each of them with full powers of substitution, as his or her true and lawful attorney-in-fact and agent to execute in his or her name and on his or her beha

August 22, 2018

Kathleen H Moriarty Partner 1270 Avenue of the Americas 30th Floor New York, New York 10020-1708 T 212.

(iii) Code of Ethics of Vantage Consulting Group is incorporated herein by reference to Exhibit (p)(iii) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (p)(iii) Vantage Consulting Group, Inc. Code of Ethics and Insider Trading Adopted February 23, 2016 1 Exhibit (p)(iii) Definitions The following defined terms are used throughout this Manual and Code of Ethics. Other terms are defined within specific sections of the Manual or Code. • Access Person - An Access Person is an Employee who has access to non-public information regarding trading

(ii) Code of Ethics of Syntax Advisors, LLC is incorporated herein by reference to Exhibit (p)(ii) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (p)(ii) APPENDIX C Syntax Advisor, LLC and Syntax ETF Trust Joint Code of Ethics Section I: Statement of General Fiduciary Principles This Joint Code of Ethics (the "Code") has been adopted by Syntax ETF Trust (the “Trust”)1 and Syntax Advisor, LLC, the investment Advisor of the Trust ("Syntax”).

(iv) Expense Limitation and Reimbursement Agreement between the Registrant and the Syntax Advisors, LLC, is incorporated herein by reference to Exhibit (d)(iii) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (d)(iii) SYNTAX ETF TRUST EXPENSE LIMITATION AND REIMBURSEMENT AGREEMENT AGREEMENT made as of March 28, 2018 by and between Syntax ETF Trust (the "Trust"), on behalf of the series listed on Schedule A (the ?Fund?), and Syntax Advisors, LLC (the "Advisor"): W I T N E S S E T H: WHEREAS, the Trust is registered as such under the Investment Company Act of 1940, as amended (the "1940 Act"); and a management investment company; and WHEREAS, the Advisor is registered as an investment adviser under the Investment Advisers Act of 1940, and will serve as the investment adviser of the Fund; NOW, THEREFORE, the parties hereto agree as follows: 1.

(i) Code of Ethics of the Registrant is incorporated herein by reference to Exhibit (p)(i) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

EX-99.(P)(I) 11 tv499452ex99-pi.htm CODE OF ETHICS OF THE REGISTRANT Exhibit (p)(i) SYNTAX ETF TRUST (the “Trust”) Code of Ethics Pursuant to Rule 17j-1 of the Investment Company Act of 1940 A. Definitions 1. “1940 Act” shall mean the Investment Company Act of 1940, as amended. 2. “Access Person” shall have the same meaning as that set forth in Rule 17j-1(a)(1) of the 1940 Act. 3. “Adviser” shall

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

N-1A/A 1 tv499452n1aa.htm N-1A/A As filed with the Securities and Exchange Commission on August 22, 2018 1933 Act Registration No. 333-215607 1940 Act Registration No. 811-23227 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 þ Pre-Effective Amendment No. 5 þ Post-Effective Amendment No. ¨ and/or REGISTRATION

(iii) Fund CCO and AMLO Agreement with Foreside Fund Officer Services, LLC, is incorporated herein by reference to Exhibit (h)(iii) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (h)(iii) FUND CCO AND AMLO AGREEMENT THIS AGREEMENT is made as of July 24, 2017, by and between Syntax ETF Trust, a Delaware statutory trust with its principal office and place of business at 110 East 59th Street, 31st Floor, New York, NY 10022 (the “Fund Company”), and Foreside Fund Officer Services, LLC, a Delaware limited liability company, with its principal office and place of business at Three Canal Plaza, Portland, Maine 04101 (“Foreside”).

Rule 12b-1 Plan, is incorporated herein by reference to Exhibit (m) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

EX-99.(M) 10 tv499452ex99-m.htm RULE 12B-1 PLAN Exhibit (m) SYNTAX ETF TRUST Rule 12b-1 Distribution and Service Plan 1. The Trust. Syntax ETF Trust (the "Trust") is an open-end management investment company registered as such under the Investment Company Act of 1940, as amended (the "1940 Act"), and organized as a series trust (each such series is referred to herein as a "Fund"). 2. The Plan. The

Master Custodian Agreement by and between Registrant and State Street Bank and Trust Company, is incorporated herein by reference to Exhibit (g) of Pre-Effective Amendment 5, as filed with the SEC on August 22, 2018.

Exhibit (g) Execution copy Master Custodian Agreement This Agreement is made as of July 20, 2017 (this “Agreement”), between each management investment company identified on Appendix A and each management investment company which becomes a party to this Agreement in accordance with the terms hereof (in each case, a “Fund”), including, if applicable, each series of the Fund identified on Appendix A and each series which becomes a party to this Agreement in accordance with the terms hereof, and State Street Bank and Trust Company, a Massachusetts trust company (the “Custodian”).

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

As filed with the Securities and Exchange Commission on December 6 , 2017 1933 Act Registration No.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

As filed with the Securities and Exchange Commission on June 20, 2017 1933 Act Registration No.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

N-1A/A 1 v469031n1aa.htm N-1A/A As filed with the Securities and Exchange Commission on June 16, 2017 1933 Act Registration No. 333-215607 1940 Act Registration No. 811-23227 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 þ Pre-Effective Amendment No. 2 þ Post-Effective Amendment No. ¨ and/or REGISTRATION ST

Syntax Etf Trust CORRESP - -

Kathleen H. Moriarty Partner +1 212.836.8276 Direct [email protected] June 16, 2017 VIA EDGAR Edward P. Bartz Senior Counsel Securities and Exchange Commission 100 F. Street, NE Washington, D.C. 20549 Re: Syntax ETF Trust - File Nos. 333-215607 and 811-23227 Dear Mr. Bartz: On behalf of Syntax ETF Trust (the “Trust”), and together with this correspondence, we are filing with the Securitie

Syntax Etf Trust CORRESP - -

Kathleen H. Moriarty Attorney +1 212 836-8276 Direct [email protected] March 24, 2017 VIA EDGAR CORRESPONDENCE Mr. Edward P. Bartz, Senior Counsel United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549-0102 RE: Syntax ETF Trust ? SEC File Nos. 333-215607 and 811-23227 (the ?Registrant?) Dear Mr. Bartz: On behalf of the Regi

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

As filed with the Securities and Exchange Commission on March 24, 2017 1933 Act Registration No.

LETTER

February 17, 2017 Kathleen H. Moriarty, Esq. Arnold & Porter Kaye Scholer LLP 250 West 55th Street New York, New York 10019-9710 Re: Syntax ETF Trust File Nos. 333-215607 and 811-23227 Dear Ms. Moriarty: On January 18, 2017, you filed a registration statement on Form N-1A for Syntax ETF Trust (the "Trust"), consisting of eleven separate exchange traded fund series: Syntax Stratified Core ETF, Synt

Syntax Etf Trust TEXT-EXTRACT - -

February 17, 2017 Kathleen H. Moriarty, Esq. Arnold & Porter Kaye Scholer LLP 250 West 55th Street New York, New York 10019-9710 Re: Syntax ETF Trust File Nos. 333-215607 and 811-23227 Dear Ms. Moriarty: On January 18, 2017, you filed a registration statement on Form N-1A for Syntax ETF Trust (the "Trust"), consisting of eleven separate exchange traded fund series: Syntax Stratified Core ETF, Synt

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940 The undersigned investment company hereby notifies the Securities and Exchange Commission that it registers under and pursuant to the provisions of Section 8(a) of the Investment Company Act of 1940 and in connection wit

Declaration of Syntax ETF Trust (“Registrant”) is incorporated herein by reference to Exhibit (a) of the Registrant’s Initial Registration Statement on Form N-1A, as filed with the SEC on January 18, 2017.

N-1A 1 v456836n1a.htm N-1A As filed with the Securities and Exchange Commission on January 18, 2017 1933 Act Registration No. [] 1940 Act Registration No. 811-23227 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 þ Pre-Effective Amendment No. o Post-Effective Amendment No. o and/or REGISTRATION STATEMENT UNDE

SYNTAX ETF TRUST

Exhibit (b) SYNTAX ETF TRUST BYLAWS These Bylaws of Syntax ETF Trust, a Delaware statutory trust (the “Trust”), are subject to the Declaration of Trust, dated January 12, 2017, as from time to time amended, supplemented or restated (the “Trust Agreement”).

Syntax Stratified Core ETF Syntax Stratified LargeCap ETF Syntax Stratified MidCap ETF Syntax Stratified Financials ETF Syntax Stratified Energy ETF Syntax Stratified Industrials ETF Syntax Stratified Information Tools ETF Syntax Stratified Informati

Kathleen H. Moriarty Attorney +1 212 836-8276 Direct [email protected] January 18, 2017 VIA EDGAR Securities and Exchange Commission Washington, D.C. 20549 Re: Form N-1A Filing for Syntax ETF Trust Registration No.: [ ] Dear Sir or Madam: On behalf of our client, Syntax ETF Trust (“Trust”), filed with this correspondence is a registration statement on Form N-1A concerning the registration

Declaration of Syntax ETF Trust (“Registrant”) is incorporated herein by reference to Exhibit (a) of the Registrant’s Initial Registration Statement on Form N-1A, as filed with the SEC on January 18, 2017.

Exhibit (a) SYNTAX ETF TRUST DECLARATION OF TRUST This DECLARATION OF TRUST (hereinafter ?Declaration of Trust?) is made as of January 12, 2017 by the trustees party hereto (together with all other persons from time to time duly elected, qualified and serving as Trustees in accordance with Article 5 hereof, the ?Trustees?).