JOHN H. LIVELY, Managing Partner
john.lively@practus.com
11300 Tomahawk Creek Pkwy., Suite 310
Leawood, KS 66211
(913) 660-0778
September 13, 2023
Ms. Karen Rossotto
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | ETF Opportunities Trust (File Nos. 333-234544 and 811-23439) |
REX IncomeMax AMD Strategy ETF
REX IncomeMax AMZN Strategy ETF
REX IncomeMax TSLA Strategy ETF
REX IncomeMax BIIB Strategy ETF
REX IncomeMax DIS Strategy ETF
REX IncomeMax EEM Strategy ETF
REX IncomeMax GDXJ Strategy ETF
REX IncomeMax GOOG Strategy ETF
REX IncomeMax META Strategy ETF
REX IncomeMax MSFT Strategy ETF
REX IncomeMax MSTR Strategy ETF
REX IncomeMax PYPL Strategy ETF
REX IncomeMax SLV Strategy ETF
REX IncomeMax SMH Strategy ETF
REX IncomeMax SNOW Strategy ETF
REX IncomeMax TLRY Strategy ETF
REX IncomeMax V Strategy ETF
Dear Ms. Rossotto:
This letter provides a response of ETF Opportunities Trust (the “Trust” or the “Registrant”) to the comment of the staff of the U.S. Securities and Exchange Commission (the “Commission”) that you provided to Practus, LLP on September 8, 2023. For your convenience, I have summarized the comment in this letter and provided the Trust’s response below the comment.
Ms. Karen Rossotto
U.S. Securities and Exchange Commission
September 13, 2023
Preliminary or General Comments
Please file this comment response letter on EDGAR.
Response: As requested, the Trust will file this comment response letter on EDGAR.
| 1. | Comment: Please provide a representation that each Fund’s underlying corporate issuer (i.e., the reference asset) is exchange listed and has been for at least a year. In addition, please provide a representation that each Fund’s underlying corporate issuer has disclosed in their respective Form 10-K that their respective market capitalization is in excess of $75 million. To the extent the reference asset is another investment company, you may make a similar representation based on information on the investment company’s website. |
| Response: REX Advisers, LLC, the investment adviser for each Fund (the “Adviser”), has represented to Practus, LLP and the Trust that each Fund’s underlying corporate issuer is exchange listed and has been for at least a year. In addition, the Adviser has represented that each Fund’s underlying corporate issuer has disclosed in their respective Form 10-K that their respective market capitalization is in excess of $75 million, and where the reference asset is another investment company, the investment company’s website or other reliable publicly available information reasonably suggest the investment company has in excess of $75 million in market capitalization. |
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Please contact me at (913) 660-0778 regarding the responses contained in this letter.
Sincerely,
/s/ John H. Lively
John H. Lively
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