BCI / abrdn ETFs - abrdn Bloomberg All Commodity Strategy K-1 Free ETF - تصريحات هيئة الأوراق المالية والبورصات، التقرير السنوي، بيان الوكيل

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May 16, 2025 VIA EDGAR Christina DiAngelo Fettig Division of Investment Management Securities and Exchange Commission 100 F Street, N.

See accompanying notes to the consolidated financial statements.

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2022 (Unaudited) Shares or Principal Amount Value SHORT-TERM INVESTMENTS—99.

See accompanying notes to the consolidated financial statements.

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2022 (Unaudited) Shares or Principal Amount Value SHORT-TERM INVESTMENTS—99.

See accompanying notes to the consolidated financial statements.

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2022 (Unaudited) Shares or Principal Amount Value SHORT-TERM INVESTMENTS—99.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, DC 20549 SCHEDULE 14C (RULE 14c-101) SCHEDULE 14C INFORMATION Information Statement Pursuant to Section 14(c) of the Securities Exchange Act of 1934 Check the appropriate box: ☐ Preliminary information statement ☐ Confidential, for use of the Commission only (as permitted by Rule 14c-5(d)(2)) ☒ Definitive information statement abrdn ETFs (Name of Registrant as Specified in Its Charter) Payment of Filing Fee (Check all boxes that apply): ☒ No fee required.

Cira Centre

Cira Centre 2929 Arch Street Philadelphia, PA 19104-2808 +1 215 994 4000 Main +1 215 994 2222 Fax www.

See accompanying notes to the consolidated financial statements.

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2022 (Unaudited) Shares or Principal Amount Value SHORT-TERM INVESTMENTS—99.

See accompanying notes to the consolidated financial statements.

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2022 (Unaudited) Shares or Principal Amount Value SHORT-TERM INVESTMENTS—99.

See accompanying notes to the consolidated financial statements.

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2022 (Unaudited) Shares or Principal Amount Value SHORT-TERM INVESTMENTS—99.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. )

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ? Filed by a Party other than the Registrant ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by

Consolidated Schedule of Portfolio Investments

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF March 31, 2022 (Unaudited) Shares or Principal Amount (US$) Value (US$) SHORT-TERM INVESTMENTS (94.

Consolidated Schedule of Portfolio Investments

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF March 31, 2022 (Unaudited) Shares or Principal Amount (US$) Value (US$) SHORT-TERM INVESTMENTS (94.

Consolidated Schedule of Portfolio Investments

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF March 31, 2022 (Unaudited) Shares or Principal Amount (US$) Value (US$) SHORT-TERM INVESTMENTS (94.

Consolidated Schedule of Portfolio Investments

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2021 (Unaudited) Shares or Principal Amount (US$) Value (US$) SHORT-TERM INVESTMENTS (98.

Consolidated Schedule of Portfolio Investments

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2021 (Unaudited) Shares or Principal Amount (US$) Value (US$) SHORT-TERM INVESTMENTS (98.

Consolidated Schedule of Portfolio Investments

Consolidated Schedule of Portfolio Investments abrdn Bloomberg All Commodity Strategy K-1 Free ETF September 30, 2021 (Unaudited) Shares or Principal Amount (US$) Value (US$) SHORT-TERM INVESTMENTS (98.

Certificate of Establishment and Designation of Series and Share Classes, dated August 27, 2021, is filed herewith.

abrdn ETFs 8-A12B Exhibit 99(i) Aberdeen Standard Investments ETFs Certificate of Establishment and Designation of Series and Share Classes The undersigned, Secretary of Aberdeen Standard Investments ETFs (the ?Trust?), a multi-series Delaware statutory trust registered as a management investment company under the Investment Company Act of 1940, as amended (the ?1940 Act?), does hereby certify tha

Registrant’s By-Laws adopted August 4, 2014, as amended and restated on September 22, 2021, are filed herewith.

abrdn ETFs 8-A12B Exhibit 99(j) By-Laws of abrdn ETFs (formerly, Aberdeen Standard Investments ETFs and ETFS Trust) as amended and restated on September 22, 2021 ARTICLE I Fiscal Year and Offices Section 1.

Certificate of Amendment effective September 22, 2021 to the Registrant’s Certificate of Trust, as filed with the State of Delaware on September 2, 2021, is filed herewith.

abrdn ETFs 8-A12B Exhibit 99(c) State of Delaware Secretary of State Division of Corporations Delivered 10:48 AM 09/02/2021 FILED 10:48 AM 09/02/2021 SR 20213151518 ? File Number 5463698 STATE OF DELAWARE CERTIFICATE OF AMENDMENT TO CERTIFICATE OF TRUST Pursuant to Title 12, Section 3810(b) of the Delaware Statutory Trust Act, the undersigned Trust executed the following Certificate of Amendment: 1.

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 abrdn ETFs (Exact name of registrant as specifi

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 abrdn ETFs (Exact name of registrant as specified in its charter) Delaware (State of incorporation or organization) See below (IRS Employer Identification No.) c/o abrdn ETFs 712 Fifth Avenue ? 49t

Form of Authorized Participant Agreement is filed herewith.

abrdn ETFs 8-A12B Exhibit 99(k) AUTHORIZED PARTICIPANT AGREEMENT FOR abrdn ETFs This Authorized Participant Agreement (the ?Agreement?) is entered into by and between ALPS Distributors, Inc.

Amendment No. 2, dated August 27, 2021, to the Declaration of Trust is filed herewith.

abrdn ETFs 8-A12B Exhibit 99(f) AMENDMENT NO. 2 TO THE DECLARATION OF TRUST OF ABERDEEN STANDARD INVESTMENTS ETFs This Amendment No. 2 dated August 27, 2021 (?Amendment No. 2?) to the DECLARATION OF TRUST of Aberdeen Standard Investments ETFs (the ?Trust?) dated January 9, 2014, which was amended effective as of October 1, 2018 (?Declaration of Trust?), is made by the Trustees hereunder: WHEREAS,

August 3, 2021

August 3, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management Disclosure Review and Accounting Office 100 F Street, N.E. Washington, D.C. 20549 Attn: Karen Rossotto Re: Aberdeen Standard Investments ETFs Registration Statement filed on Form N-1A File Nos. 333-198170 and 811-22986 Dear Ms. Rossotto: On behalf of Aberdeen Standard Investments ETFs (the ?Registran

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July 26, 2021 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management Disclosure Review and Accounting Office 100 F Street, N.E. Washington, D.C. 20549 Attn: Karen Rossotto Re: Aberdeen Standard Investments ETFs Registration Statement filed on Form N-1A File Nos. 333-198170 and 811-22986 Dear Ms. Rossotto: On behalf of Aberdeen Standard Investments ETFs (the ?Registrant

One International Place, 40th Floor

One International Place, 40th Floor 100 Oliver Street Boston, MA 02110-2605 +1 617 728 7100 Main +1 617 426 6567 Fax www.

See accompanying notes to consolidated schedules of portfolio investments.

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2021 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 95.

See accompanying notes to consolidated schedules of portfolio investments.

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2021 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 95.

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January 29, 2021 VIA EDGAR Christina DiAngelo Fettig Division of Investment Management Securities and Exchange Commission 100 F Street, N.

See accompanying notes to consolidated schedules of portfolio investments.

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments September 30, 2020 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 93.

See accompanying notes to consolidated schedules of portfolio investments.

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments September 30, 2020 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 93.

See accompanying notes to consolidated schedules of portfolio investments.

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2020 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 92.

See accompanying notes to consolidated schedules of portfolio investments.

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2020 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 92.

BCI / Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF AW - - WITHDRAWAL OF AMENDMENT TO A REGISTRATION STATEMENT

VIA EDGAR February 28, 2020 U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Aberdeen Standard Investments ETFs (File Nos. 333-198170 and 811-22986) Request for Withdrawal of Post-Effective Amendment No. 17 Ladies and Gentlemen: Pursuant to Rule 477 under the Securities Act of 1933 (the “1933 Act”), Aberdeen Standard Investments ETFs (the “Trust”) respectfully requ

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 March 02, 2020, pursuant to the provisions of Rule 12d2-2 (a).

BCD / Aberdeen Standard Bloomberg All Commodity Longer Dated Strategy K-1 Free ETF NPORT-EX - -

NPORT-EX 2 ABDStandardPartF93019.htm Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments September 30, 2019 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 99.1% U.S. TREASURY OBLIGATIONS - 99.1% U.S. Treasury Bills 2.12%, 10/10/2019(a) 2,300,000 2,298,987 2.40%, 10/17/2019

BCI / Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF NPORT-EX - -

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments September 30, 2019 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 99.

AOIL / Aberdeen Standard Bloomberg WTI Crude Oil Strategy K-1 Free ETF NPORT-EX - -

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments September 30, 2019 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 99.

Etfs Trust NPORT-EX - -

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2019 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 97.

Etfs Trust NPORT-EX - -

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2019 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 97.

Etfs Trust NPORT-EX - -

Aberdeen Standard Investments ETFs Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF Consolidated Schedule of Portfolio Investments March 31, 2019 (Unaudited) Investments Principal Amount ($) Value ($) SHORT-TERM INVESTMENTS - 97.

Etfs Trust CORRESP - -

CORRESP 1 filename1.htm VIA EDGAR May 8, 2019 Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Aberdeen Standard Investments ETFs (the “Registrant”) – File Nos.: 333-198170 and 811-22986 Ladies and Gentlemen: On behalf of the Registrant, please find attached for filing Post-Effective Amendment No. 17 to the Registrant’s Registration Statement under the Securities Act of

Etfs Trust CORRESP - -

April 23, 2019 VIA EDGAR Ms. Alison T. White Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Aberdeen Standard Investments ETFs; File Nos. 333-191870 and 811-22986 Dear Ms. White: On behalf of Aberdeen Standard Investments ETFs (the “Trust”), this letter responds to the Staff comments we received orally on April 12, 2019 regarding

VIA EDGAR

VIA EDGAR March 1, 2019 Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Aberdeen Standard Investments ETFs (the ?Registrant?) ? File Nos.: 333-198170 and 811-22986 Ladies and Gentlemen: On behalf of the Registrant, please find attached for filing Post-Effective Amendment No. 15 to the Registrant?s Registration Statement under the Securities Act of 1933, as amended (the

CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002

EX-99.CERT 2 ex99-cert.htm CERTIFICATION Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Bev Hendry, certify that: 1. I have reviewed this report on Form N-Q of Aberdeen Standard Investments ETFs; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omi

Etfs Trust QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS (Quarterly Schedule of Portfolio Holdings)

N-Q 1 asi-nq093018.htm QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 Aberdeen Standard Investments ETFs (Exact name of registrant as specified in charter) 1735 Market Street, 32nd Floor Philade

Etfs Trust ADDITIONAL DEFINITIVE MATERIALS

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant?? Filed by a Party other than the Registrant?? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ? Defin

Etfs Trust ADDITIONAL DEFINITIVE MATERIALS

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ☐ Defin

Etfs Trust ADDITIONAL DEFINITIVE PROXY SOLICITING MATERIALS

DEFA14A 1 etfs-defa14a082718.htm ADDITIONAL DEFINITIVE PROXY SOLICITING MATERIALS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☐ Preliminary Proxy Statement ☐ Confi

Etfs Trust ADDITIONAL DEFINITIVE PROXY SOLICITING MATERIALS

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ? Filed by a Party other than the Registrant ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule 14a-6(e)(2)) ? Defin

Etfs Trust DEFINITIVE PROXY STATEMENT

etfs-def14a082718 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ? Filed by a Party other than the Registrant ? Check the appropriate box: ? Preliminary Proxy Statement ? Confidential, for Use of the Commission Only (as permitted by Rule 14

Etfs Trust CORRESP

K. Michael Carlton Associate +1.202.373.6070 [email protected] July 2, 2018 VIA EDGAR Ms. Alison T. White Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust; File No. 811-22986 Dear Ms. White: On behalf of our client, ETFS Trust (the “Registrant”), we are responding to Staff comments we received on June 15, 2

Etfs Trust PRELIMINARY PROXY STATEMENT

etfs-pre14a060718 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 (Amendment No. ) Filed by the Registrant ☒ Filed by a Party other than the Registrant ☐ Check the appropriate box: ☒ Preliminary Proxy Statement ☐ Confidential, for Use of the Commission Only (as permitted by Rule 14

Etfs Trust N-Q (Quarterly Schedule of Portfolio Holdings)

N-Q 1 etfs-nq033118.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 712 Fifth Avenue New York, New York 10019 (Address of principal executive offices) (Zip code) The Corp

Certifications pursuant to Rule 30a-2(a) under the Investment Company Act of 1940 are attached hereto.

Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Bev Hendry, certify that: 1. I have reviewed this report on Form N-Q of ETFS 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,

EX-99.77Q1 OTHR EXHB

ETFS TRUST FORM OF AMENDMENT TO INVESTMENT ADVISORY AGREEMENT This Amendment (the ?Amendment?) is made and entered into as of December 5, 2017, and hereby amends the Investment Advisory Agreement, dated December 2, 2014 (the ?Agreement?), between ETF Securities Advisors LLC (the ?Adviser?) and ETFS Trust, a statutory trust organized under the laws of the State of Delaware (the ?Trust?), on behalf of each series of the Trust as listed on Schedule A of the Agreement, as revised from time to time (the ?Funds?).

EX-99.77B ACCT LTTR

EX-99.77B ACCT LTTR 2 a77bauditorinternalcontrolle.htm EX-99.77B ACCT LTTR REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders and Board of Trustees of ETFS Trust In planning and performing our audit of the consolidated financial statements of ETFS Trust comprising ETFS Bloomberg All Commodity Strategy K-1 Free ETF, ETFS Bloomberg All Commodity Longer Dated Strategy K-1 Fre

Etfs Trust - QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS

N-Q 1 etfs-nq093017.htm QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 405 Lexington Avenue New York, New York 10174 (Address of pri

Certifications pursuant to Rule 30a-2(a) under the Investment Company Act of 1940 are attached hereto.

ETFS Trust N-Q Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Graham Tuckwell, certify that: 1. I have reviewed this report on Form N-Q of ETFS 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

EX-99.77K CHNG ACCNT

Change in Auditor In March 2017, KPMG LLP ("KPMG") had declined to stand for reappointment as the independent registered public accounting firm to the Trust and the Board of Trustees approved the engagement of Cohen & Company, Ltd.

EX-99.77Q1 OTHR EXHB

VIA EDGAR October 13, 2017 U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attention: File Room Re: ETFS Trust (File Nos. 811-22986) Amended Form N-SAR Filing Ladies and Gentlemen: On behalf of ETFS Trust (the "Trust"), we are filing an amended Form N-SAR, under the Investment Company Act of 1940 and Rule 30b1-1 thereunder, for the reporting period ended June 30, 2017

EX-99.77K CHNG ACCNT

EX-99.77K CHNG ACCNT 2 changeinauditor77k.htm EX-99.77K CHNG ACCNT Change in Auditor In March 2017, following a competitive review of independent registered public accounting firms, KPMG LLP ("KPMG") ceased to act as the independent registered public accounting firm to the Trust and the Board of Trustees approved the engagement of Cohen & Company, Ltd. as the new independent registered public acco

CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002

EX-99.CERT 2 ex99-certs.htm CERTIFICATIONS ETFS Trust N-Q Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Graham Tuckwell, certify that: 1. I have reviewed this report on Form N-Q of ETFS Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit

Etfs Trust - QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS

N-Q 1 etfs-nq033117.htm QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 405 Lexington Avenue New York, New York 10174 (Address of pri

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 ETFS Trust (Exact name of registrant as specifi

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 ETFS Trust (Exact name of registrant as specified in its charter) Delaware (State of incorporation or organization) See below (IRS Employer Identification No.) c/o ETFS Trust 405 Lexington Avenue N

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CORRESP 1 filename1.htm K. Michael Carlton Associate +1.202.373.6070 [email protected] March 20, 2017 VIA EDGAR Ms. Alison T. White Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust File Nos. 333-191870 and 811-22986 Dear Ms. White: On behalf of our client, ETFS Trust (the “Trust”), we are responding to Staf

Statement of Additional Information

K. Michael Carlton Associate +1.202.373.6070 [email protected] March 15, 2017 VIA EDGAR Ms. Alison T. White Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust File Nos. 333-191870 and 811-22986 Dear Ms. White: On behalf of our client, ETFS Trust (the “Trust”), we are responding to Staff comments we received t

EX-99.77B ACCT LTTR

Report of Independent Registered Public Accounting Firm The Board of Trustees and Shareholders ETFS Trust: In planning and performing our audits of the financial statements of ETFS Zacks Earnings Large-Cap U.

EX-99.25

EX-99.25 2 ruleprovisionnotice.htm NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES The NYSE Archipelago Exchange 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 February 10, 2017, pursuant to the provisions of Rule 12d2-2 (a). [ X ] 17 CFR 240.

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES The NYSE Archipelago Exchange 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 February 10, 2017, pursuant to the provisions of Rule 12d2-2 (a).

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K. Michael Carlton +1.202.373.6070 [email protected] December 16, 2016 VIA EDGAR Mr. David Manion Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust File Nos. 333-191870 and 811-22986 Dear Mr. Manion: On behalf of our client, ETFS Trust (the “Trust”), we are responding to Staff comments we received orally on

EX-99.25

EX-99.25 2 ruleprovisionnotice.htm NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES The NYSE Archipelago Exchange 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 December 12, 2016, pursuant to the provisions of Rule 12d2-2 (a). [ X ] 17 CFR 240.

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES The NYSE Archipelago Exchange 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 December 12, 2016, pursuant to the provisions of Rule 12d2-2 (a).

Certifications pursuant to Rule 30a-2(a) under the Investment Company Act of 1940 are attached hereto

EX-99.CERT 2 ex-99cert.htm CERTIFICATIONS ETFS Trust N-Q Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Graham Tuckwell, certify that: 1. I have reviewed this report on Form N-Q of ETFS Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit t

Etfs Trust - QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS

N-Q 1 etfs-nq093016.htm QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 48 Wall Street New York, New York 10005 (Address of principal

W. John McGuire

W. John McGuire +1.202.373.6799 [email protected] VIA EDGAR November 14, 2016 U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust (File Nos. 333-198170 and 811-22986) Filing Pursuant to Rule 485(b) Ladies and Gentlemen: On behalf of our client, ETFS Trust (the “Trust”), we are filing, pursuant to Rule 485(a) under the Securities Act of 1933, as amen

CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002

EX-99.CERT 2 ex-99cert.htm CERTIFICATIONS ETFS Trust N-Q Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Graham Tuckwell, certify that: 1. I have reviewed this report on Form N-Q of ETFS Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit t

Etfs Trust - QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS

N-Q 1 etfs-nq033116.htm QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 48 Wall Street New York, New York 10005 (Address of principal

Prospectus - ETFS Zacks Earnings Large-Cap U.S. Index Fund

K. Michael Carlton +1.202.373.6070 [email protected] April 29, 2016 VIA EDGAR Ms. Sumeera Younis Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust File Nos. 333-191870 and 811-22986 Dear Ms. Younis: On behalf of our client, ETFS Trust (the ?Trust?), we are responding to Staff comments we received orally on A

W. John McGuire

W. John McGuire +1.202.373.6799 [email protected] VIA EDGAR March 3, 2016 U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust (File Nos. 333-198170 and 811-22986) Filing Pursuant to Rule 485(a) Ladies and Gentlemen: On behalf of our client, ETFS Trust (the ?Trust?), we are filing, pursuant to Rule 485(a) under the Securities Act of 1933, as amended,

EX-99.77K CHNG ACCNT

Change in Auditor In December 2015, following a competitive review of independent registered public accounting firms, Deloitte & Touche LLP (?D&T?) ceased to act as the independent registered public accounting firm to the Trust and the Board of Trustees approved the engagement of KPMG LLP (?KPMG?) as the new independent registered public accounting firm for the Funds? fiscal year ending December 31, 2015.

EX-99.77B ACCT LTTR

Report of Independent Registered Public Accounting Firm The Board of Trustees and Shareholders ETFS Trust: In planning and performing our audits of the financial statements of ETFS Zacks Earnings Large-Cap U.

Etfs Trust - QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS

N-Q 1 etfs-nq093015.htm QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 48 Wall Street New York, New York 10005 (Address of principal

CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002

EX-99.CERT 2 e64167ex99cert.htm CERTIFICATION Exhibit 99.CERT CERTIFICATION PURSUANT TO RULE 30a-2(a) UNDER THE INVESTMENT COMPANY ACT OF 1940 AND SECTION 302 OF THE SARBANES OXLEY ACT OF 2002 I, Benoit Autier, certify that: 1. I have reviewed this report on Form N-Q of ETFS Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a mat

Etfs Trust - FORM N-Q

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number: 811-22986 ETFS TRUST (Exact name of registrant as specified in charter) 48 Wall Street New York, New York 10005 (Address of principal executive offices) (Zip code) The Corporation Trust Company 1209

Etfs Trust 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 ETFS Trust - (Exact name of registrant as specified in its charter) Delaware - (State of incorporation or organization) See below - (IRS Employer Identification No.) ETFS Trust 48 Wall Street 11th

DISTRIBUTION AGREEMENT

Exhibit 99(e)(1) DISTRIBUTION AGREEMENT THIS AGREEMENT is made as of December 22, 2014, between ETFS Trust, a Delaware statutory trust (the “Fund”), and ALPS Distributors, Inc.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Exhibit 99.(j) CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the use in this Pre-Effective Amendment No. 2 to Registration Statement No. 333-198170 on Form N-1A of our report dated January 7, 2015, relating to the financial statement of ETFS Zacks Earnings Small-Cap U.S. Index Fund, a portfolio of ETFS Trust, appearing in the Statement of Additional Information, which is p

Distribution and Service Plan, adopted December 2, 2014 (the “Distribution and Service Plan”), is incorporated herein by reference to Exhibit (m) of Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File Nos. 333-198170 and 811-22986), as filed with the SEC via EDGAR Accession No. 0000930413-15-000063 on January 7, 2015.

EX-99.(M) 11 c78447ex99-m.htm Exhibit 99.(m) DISTRIBUTION AND SERVICE PLAN This Distribution and Service Plan (the “Plan”) has been adopted, on the following terms and conditions, by the Board of Trustees (the “Trustees”) of ETFS Trust (the “Trust”), a registered, open-end management investment company under the Investment Company Act of 1940, as amended (the “1940 Act”), pursuant to Rule l2b-1 un

AGENCY SERVICES AGREEMENT

EX-99.(H)(2) 8 c78447ex99-h2.htm Exhibit 99(h)(2) THIS AGREEMENT IS TO BE ONLY USED FOR THE PROVISION OF AGENCY SERVICES TO A UNITED STATES EXCHANGE-TRADED FUND AGENCY SERVICES AGREEMENT THIS AGENCY SERVICES AGREEMENT made as of the 4th day of December, 2014 by and between ETFS TRUST, a Delaware statutory trust and registered investment company under the Investment Company Act of 1940, as amended

THIS AGREEMENT IS TO BE ONLY USED FOR THE PROVISION OF ADMINISTRATION SERVICES TO A UNITED STATES EXCHANGE-TRADED FUND TABLE OF CONTENTS

Exhibit 99.(h)(1) THIS AGREEMENT IS TO BE ONLY USED FOR THE PROVISION OF ADMINISTRATION SERVICES TO A UNITED STATES EXCHANGE-TRADED FUND TABLE OF CONTENTS SECTION 1. INTENTION OF THE PARTIES; DEFINITIONS 2 1.1 Intention of the Parties. 2 1.2 Definitions; Interpretation. 2 2. WHAT J.P. MORGAN IS REQUIRED TO DO 5 2.1 The Services. 5 2.2 No Duty to Monitor Compliance. 5 2.3 No Responsibility for Tax

Etfs Trust N-1A/A - -

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON JANUARY 7, 2015 File No. 333-198170 File No. 811-22986 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ý PRE-EFFECTIVE AMENDMENT NO. 2 ý POST-EFFECTIVE AMENDMENT NO. o and/or REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 ý AMENDMENT NO. 2 ý

INVESTMENT ADVISORY AGREEMENT

EX-99.(D)(1) 2 c78447ex99-d1.htm Exhibit 99.(d)(1) INVESTMENT ADVISORY AGREEMENT AGREEMENT (“Agreement”) made as of this 2nd day of December, 2014, between ETF Securities Advisors LLC (the “Adviser”) and ETFS Trust, a statutory trust organized under the laws of the State of Delaware (the “Trust”). WHEREAS, the Adviser is principally engaged in the business of rendering investment management servic

Etfs Trust CORRESP - -

CORRESP 40 filename40.htm Morgan, Lewis & Bockius llp 2020 K Street, NW Washington, DC 20006 Tel. +1.202.373.6000 Fax: +1.202.373.6001 www.morganlewis.com W. John McGuire +1.202.373.6799 [email protected] January 7, 2015 VIA EDGAR U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust: Registration Statement on Form N-1A (File Nos.333-198170 and 811

VTL Associates, LLC Index Management Solutions, LLC RevenueShares ETF Trust CODE OF ETHICS Effective: October 12, 2007; as amended February 23, 2011, May 30, 2012 and August 21, 2013

Exhibit 99.(p)(3) VTL Associates, LLC Index Management Solutions, LLC RevenueShares ETF Trust CODE OF ETHICS Effective: October 12, 2007; as amended February 23, 2011, May 30, 2012 and August 21, 2013 Introduction Pursuant to rules established by the U.S. Securities and Exchange Commission (the “SEC”), it is unlawful for certain persons of VTL Associates, LLC (the “Adviser”), Index Management Solu

Table of contents

Exhibit 99.(g) Global Custody Agreement - New York - General - May 2012 Table of contents 1. INTENTION OF THE PARTIES; DEFINITIONS 1 1.1 Intention of the Parties 1 1.2 Definitions; Interpretation 1 2. WHAT J.P. MORGAN IS REQUIRED TO DO 5 2.1 Set Up Accounts 5 2.2 Cash Account 6 2.3 Segregation of Assets; Nominee Name 6 2.4 Settlement of Transactions 7 2.5 Contractual Settlement Date Accounting 7 2

Almaty Astana Beijing Boston Brussels Chicago Dallas Dubai Frankfurt Harrisburg Hartford Houston London Los Angeles Miami Moscow New York Orange County Paris Philadelphia Pittsburgh Princeton San Francisco Santa Monica Silicon Valley Tokyo Washington

EX-99.(I) 9 c78447ex99-i.htm Morgan, Lewis & Bockius llp 2020 K Street, NW Washington, DC 20006 Tel. +1.202.373.6000 Fax: +1.202.373.6001 www.morganlewis.com January 7, 2015 ETFS Trust 48 Wall Street New York, NY 10005 Re: ETFS Trust Ladies and Gentlemen: We have acted as counsel to ETFS Trust, a Delaware statutory trust (the “Trust”), in connection with Pre-Effective Amendment Number 2 to the Tru

Code of Ethics

Exhibit 99.(p)(2) Code of Ethics This Code of Ethics (“Code”) is adopted in compliance with the requirements of U.S. securities laws applicable to registered investment advisers. Registered investment advisers are required by Rule 204A-1 under the Investment Advisers Act of 1940, as amended (“Advisers Act”), to adopt a code of ethics which, among other things, sets forth the standards of business

ALPS Code of Ethics

Exhibit 99.(p)(4) ALPS Code of Ethics ALPS Code of Ethics Dated: May 1, 2010 Amended Last: September 30, 2013 1 ALPS Code of Ethics Table of Contents Introduction 3 Applicability 4 General Standards of Business Conduct 8 Conflicts of Interest 8 Protecting Confidential Information 8 Insider Trading and Tipping 9 Excess Trading 9 Front Running 9 Gifts and Entertainment 9 Service on a Board of Direct

ETFS TRUST CODE OF ETHICS Adopted Pursuant to Rule 17j-1

Exhibit 99.(p)(1) ETFS TRUST CODE OF ETHICS Adopted Pursuant to Rule 17j-1 While affirming its confidence in the integrity and good faith of all of its officers and trustees, ETFS Trust (the “Trust”), recognizes that the knowledge of present or future portfolio transactions and, in certain instances, the power to influence portfolio transactions which may be possessed by certain of its officers, e

SUB-ADVISORY AGREEMENT

Exhibit 99.(d)(2) SUB-ADVISORY AGREEMENT SUB-ADVISORY AGREEMENT (the “Agreement”) made as of this 5th day of January 2015 by and between ETF Securities Advisors LLC, a Delaware limited liability company with its principal place of business at 48 Wall Street New York, NY 10005 (the “Adviser”), and Index Management Solutions LLC, a Pennsylvania limited liability company with its principal place of b

AUTHORIZED PARTICIPANT AGREEMENT ETFS TRUST

Exhibit 99.(e)(2) AUTHORIZED PARTICIPANT AGREEMENT FOR ETFS TRUST This Authorized Participant Agreement (the “Agreement”) is entered into by and between ALPS Distributors, Inc. (the “Distributor”) and (the “Authorized Participant” or “AP”) and is subject to acceptance by J.P. Morgan (“ETF Administrator” or the “Transfer Agent”). The Transfer Agent serves as the transfer agent for the ETFS Trust (t

ETFS TRUST FORM OF POWER OF ATTORNEY

EX-99.(Q) 16 c78447ex99-q.htm Exhibit 99.(q) ETFS TRUST FORM OF POWER OF ATTORNEY KNOW ALL PERSONS BY THESE PRESENTS, that the undersigned trustee of ETFS Trust (the “Trust”), a statutory trust organized under the laws of the State of Delaware, hereby constitutes and appoints Benoit Autier and Adam Rezak, and each of them singly, his true and lawful attorneys-in-fact and agents with full power of

Etfs Trust CORRESP - -

ETFS Trust 48 Wall Street New York, New York 10005 January 6, 2015 VIA EDGAR U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Catherine Courtney Gordon Re: ETFS Trust (the “Trust”): Request for Acceleration of the Effective Date of Pre-Effective Amendment No. 2 to the Trust’s Registration Statement on Form N-1A, as Filed January 6, 2015 (File Nos. 333-198170 and

Etfs Trust N-1A/A - -

N-1A/A 1 c78447n1a-a.htm AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON OCTOBER 9, 2014 File No. 333-198170 File No. 811-22986 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 S PRE-EFFECTIVE AMENDMENT NO. 1 S POST-EFFECTIVE AMENDMENT NO. £ and/or REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF

Etfs Trust CORRESP - -

October 9, 2014 U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust: Registration Statement on Form N-1A (File Nos.333-198170 and 811-22986) Ladies and Gentlemen: On behalf of our client, ETFS Trust (the “Registrant”), we are filing, pursuant to the Securities Act of 1933 (“1933 Act”), and under the Investment Company Act of 1940, Pre-Effective Amendment No

Etfs Trust CORRESP - -

October 9, 2014 VIA EDGAR Catherine C. Gordon Senior Counsel Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust File No. 811-22986 Dear Ms. Gordon: On behalf of our client, ETFS Trust (the ?Trust?), we are responding to Staff comments we received in a letter from you dated September 12, 2014 regarding the Trust?s initial f

Registrant’s Declaration of Trust dated January 9, 2014 (the “Declaration of Trust”) is incorporated herein by reference to Exhibit (a)(2) of the Registrant’s Initial Registration Statement on Form N-1A (File Nos. 333-198170 and 811-22986), as filed with the SEC via EDGAR Accession No. 0000930413-14-003692 on August 15, 2014.

Exhibit 99(a)(2) DECLARATION OF TRUST as of January 9, 2014 of ETFS TRUST a Delaware Statutory Trust TABLE OF CONTENTS ARTICLE I Name and Definitions.

Certificate of Trust of Aberdeen Standard Investments ETFs (formerly, ETFS Trust) (the “Registrant” or the “Trust”) dated January 9, 2014, as filed with the state of Delaware on January 10, 2014 (the “Certificate of Trust”), is incorporated herein by reference to Exhibit (a)(1) of the Registrant’s Initial Registration Statement on Form N-1A (File Nos. 333-198170 and 811-22986), as filed with the U.S. Securities Exchange Commission (the “SEC”) via EDGAR Accession No. 0000930413-14-003692 on August 15, 2014.

Exhibit 99(a)(1) CERTIFICATE OF TRUST of ETFS TRUST This Certificate of Trust for ETFS Trust (the ?Trust?), a statutory trust, is filed in accordance with the provisions of the Delaware Statutory Trust Act (12 Del.

August 15, 2014

CORRESP 13 filename13.htm August 15, 2014 U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: ETFS Trust: Initial Registration Statement on Form N-1A (File Nos.333- and 811-22986) Ladies and Gentlemen: On behalf of our client, ETFS Trust (the “Trust”), we are filing, pursuant to the Securities Act of 1933, and under the Investment Company Act of 1940, the Trust’s regi

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON AUGUST 15, 2014

N-1A 1 c78447n-1a.htm AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON AUGUST 15, 2014 File No. 811-22986 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 S PRE-EFFECTIVE AMENDMENT NO. ( ) POST-EFFECTIVE AMENDMENT NO. ( ) and/or REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 S AMENDMENT NO.

Registrant’s By-Laws, dated August 4, 2014, are incorporated herein by reference to Exhibit (b) of the Registrant’s Initial Registration Statement on Form N-1A (File Nos. 333-198170 and 811-22986), as filed with the SEC via EDGAR Accession No. 0000930413-14-003692 on August 15, 2014.

Exhibit 99(b) BY-LAWS OF ETFS TRUST ARTICLE I Fiscal Year and Offices Section 1. Fiscal Year. The fiscal year of the Trust or any series thereof shall be established, re-established or changed from time to time by resolution of the Board. The fiscal year of the Trust shall be the taxable year of each series of the Trust. Section 2. Delaware Office. The Board of Trustees shall establish a registere

BCI / Aberdeen Standard Bloomberg All Commodity Strategy K-1 Free ETF N-8A - -

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