GABF / Gabelli ETFs Trust - Gabelli Financial Services Opportunities ETF - Документы SEC, Годовой отчет, Доверенное заявление

Gabelli ETFs Trust - ETF возможностей финансовых услуг Gabelli
US ˙ ARCA

Основная статистика
CIK 1748425
SEC Filings
All companies that sell securities in the United States must register with the Securities and Exchange Commission (SEC) and file reports on a regular basis. These reports include company annual reports (10K, 10Q), news updates (8K), investor presentations (found in 8Ks), insider trades (form 4), ownership reports (13D, and 13G), and reports related to the specific securities sold, such as registration statements and prospectus. This page shows recent SEC filings related to Gabelli ETFs Trust - Gabelli Financial Services Opportunities ETF
SEC Filings (Chronological Order)
На этой странице представлен полный хронологический список документов SEC, за исключением документов о собственности, которые мы предоставляем в других местах.
August 23, 2024 CORRESP

Comments and Responses

August 23, 2024 VIA EDGAR Christina DiAngelo Fettig Division of Investment Management Disclosure Review and Accounting Office U.

July 2, 2024 CORRESP

******* Comments and Responses

July 2, 2024 VIA EDGAR Christina DiAngelo Fettig Division of Investment Management Disclosure Review and Accounting Office U.

May 15, 2024 CORRESP

******* Comments and Responses

May 15, 2024 VIA EDGAR Christina DiAngelo Fettig Division of Investment Management Disclosure Review and Accounting Office U.

March 6, 2023 CORRESP

2

Gabelli ETF Trusts (212) 318-6960 [email protected] March 6, 2023 Mr. Bernard Nolan U.S. Securities and Exchange Commission (the “SEC”) Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Trust”) File Numbers: 333-238109; 811-23568 Dear Mr. Nolan: This letter responds to comments provided by you to the undersigned firm with respe

January 4, 2023 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 GABELLI ETFs TRUST (Exact Name of Registrant as

GABELLI ETFs TRUST UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.

November 29, 2022 NPORT-EX

Cl. A

1 Gabelli Growth Innovators ETF Schedule of Investments — September 30, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 100.

November 29, 2022 NPORT-EX

Cl. A†

1 Gabelli Love Our Planet & People ETF Schedule of Investments — September 30, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 93.

November 29, 2022 NPORT-EX

Cl. B†

1 Gabelli Financial Services Opportunities ETF Schedule of Investments — September 30, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 97.

November 29, 2022 NPORT-EX

Cl. A†

1 Gabelli Automation ETF Schedule of Investments — September 30, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 100.

June 2, 2022 CORRESP

2

Gabelli ETFs Trust (212) 318-6960 [email protected] June 2, 2022 Ms. Samantha A. Brutlag U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Trust”) File Numbers: 333-238109; 811-23568 Dear Ms. Larkin: This letter responds to comments provided by you to the undersigned firm with respect to

May 31, 2022 NPORT-EX

Cl. A

1 Gabelli Love Our Planet & People ETF Schedule of Investments — March 31, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 95 .

May 31, 2022 NPORT-EX

Cl. A†

1 Gabelli Asset ETF Schedule of Investments — March 31, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 100.

May 31, 2022 NPORT-EX

Cl. A†

1 Gabelli Growth Innovators ETF Schedule of Investments — March 31, 2022 (Unaudited) Shares Market Value COMMON STOCKS – 100.

April 29, 2022 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 GABELLI ETFs TRUST (Exact Name of Registrant as

8-A12B 1 gast-8a12b042922.htm REGISTRATION / LISTING OF A CLASS OF SECURITIES 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 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE (State of Incorporation or Organizat

December 30, 2021 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 GABELLI ETFs TRUST (Exact Name of Registrant as

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 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE See Below (State of Incorporation or Organization) (I.R.S. Employer Identification No.) One Corporate Center Rye,

November 29, 2021 NPORT-EX

ADR American

1 Gabelli Growth Innovators ETF Schedule of Investments — September 30, 2021 (Unaudited) Shares Market Value COMMON STOCKS – 100 .

November 29, 2021 NPORT-EX

ADR American

1 Gabelli Love Our Planet & People ETF Schedule of Investments — September 30, 2021 (Unaudited) Shares Market Value COMMON STOCKS – 95 .

February 17, 2021 8-A12B/A

- AMENDMENT TO FORM 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-A/A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE See Below (State of Incorporation or Organization) (I.R.S. Employer Identification No.) One Corporate Center Rye

February 12, 2021 8-A12B/A

- AMENDMENT TO FORM 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-A/A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE See Below (State of Incorporation or Organization) (I.R.S. Employer Identification No.) One Corporate Center Rye

February 12, 2021 8-A12B/A

- AMENDMENT TO FORM 8-A12B

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM 8-A/A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE See Below (State of Incorporation or Organization) (I.R.S. Employer Identification No.) One Corporate Center Rye

February 11, 2021 8-A12B

- FORM FOR THE REGISTRATION/LISTING OF CLASS OF SECURITIES

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 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE See Below (State of Incorporation or Organization) (I.R.S. Employer Identification No.) One Corporate Center Rye,

January 25, 2021 RW WD

- WITHDRAWAL OF A REGISTRATION WITHDRAWAL REQUEST

1(212) 318-6736 [email protected] January 22, 2021 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A Securities Act File No. 333-238109 Ladies and Gentlemen: I am writing on behalf of the above-referenced Registrant, to respectfully request the withdrawal, effective immediate

January 25, 2021 RW WD

- WITHDRAWAL OF A REGISTRATION WITHDRAWAL REQUEST

1(212) 318-6736 [email protected] January 22, 2021 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A Securities Act File No. 333-238109 Ladies and Gentlemen: I am writing on behalf of the above-referenced Registrant, to respectfully request the withdrawal, effective immediate

January 22, 2021 RW

- REGISTRATION WITHDRAWAL REQUEST

1(212) 318-6736 [email protected] January 22, 2021 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A Securities Act File No. 333-249489 Ladies and Gentlemen: I am writing on behalf of the above-referenced Registrant, pursuant to Rule 477(a) under the Securities Act of 1933, a

January 19, 2021 8-A12B

- FORM FOR THE REGISTRATION/LISTING OF CLASS OF SECURITIES

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 GABELLI ETFs TRUST (Exact Name of Registrant as Specified in Its Charter) DELAWARE See Below (State of Incorporation or Organization) (I.R.S. Employer Identification No.) One Corporate Center Rye,

January 13, 2021 EX-99.(I)(1)

Consent of Paul Hastings, LLP.

Exhibit (i)(1) CONSENT OF COUNSEL We consent to the reference to our Firm under the heading “Counsel” in the Registration Statement on Form N-1A/A of Gabelli ETFs Trust as filed with the Securities and Exchange Commission on or about January 13, 2021. /s/ Paul Hastings LLP PAUL HASTINGS LLP New York, New York January 13, 2021

January 13, 2021 N-1A/A

- FORM N-1A/A

Securities Act File No. 333-238109 Investment Company Act File No. 812-15036 As filed with the Securities and Exchange Commission on January 13, 2021 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. 3 ☐ Post-Effective Amendment No. and/or REGISTRATION STATEMENT UNDER THE INVESTMEN

January 12, 2021 CORRESP

-

CORRESP 1 filename1.htm (212) 318-6054 [email protected] January 12, 2021 Mr. Jeffrey A. Foor U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Trust”) File Numbers: 333-238109; 811-23568 Dear Mr. Foor: This letter responds to oral comments provided by you to the undersigned with respect to t

December 28, 2020 EX-99.(D)(5)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Micro Cap ETF. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (d)(5) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Micro Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 EX-99.(D)(7)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Asset ETF. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (d)(7) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Asset ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 EX-99.(D)(3)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Global Small Cap ETF. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (d)(3) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Global Small Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 EX-99.(D)(6)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Love Our Planet &

GABELLI ETFs TRUST N-1A/A Exhibit (d)(6) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Love Our Planet & People ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 COVER

(212) 318-6054

(212) 318-6054 [email protected] December 28, 2020 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A/A File No.: 333-238109; 811-23157 Ladies and Gentlemen: On behalf of the Registrant, we hereby transmit for filing, pursuant to the S

December 28, 2020 EX-99.(D)(8)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Equity Income ETF. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (d)(8) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Equity Income ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 RW

- REGISTRATION WITHDRAWAL REQUEST

(212) 318-6736 [email protected] December 28, 2020 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A Securities Act/Investment Company Act File No. 333-238109 / 811-23568 Ladies and Gentlemen: I am writing on behalf of the above-referenced Registrant, pursuant to Rule 477(a)

December 28, 2020 EX-99.(L)

Subscription Agreement between the Registrant and Gabelli Funds, LLC. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (l) INITIAL SUBSCRIPTION AGREEMENT The Gabelli ETFs Trust (the “Trust”), a Delaware statutory trust, and Gabelli Funds, LLC (the “Purchaser”), a New York limited liability company, hereby agree as follows: 1.

December 28, 2020 EX-99.(P)

Revised Code of Ethics for the Registrant, Gabelli Funds, LLC, GAMCO Asset Management, Inc., G.research, LLC, G.distributors, LLC, Teton Advisors, Inc., Gabelli Fixed Income LLC, and Gabelli Securities, Inc., dated January 24, 2020. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (p) SECTION S Gabelli Funds, LLC GAMCO Asset Management Inc.

December 28, 2020 EX-99.(J)(1)

Consent of Independent Registered Public Accounting Firm.

EX-99.(J)(1) 16 ex-j1.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM GABELLI ETFs TRUST N-1A/A Exhibit (j)(1) CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the use in this Registration Statement on Form N-1A of Gabelli ETFs Trust of our report dated December 24, 2020, relating to the statement of assets and liabilities of Gabelli Love Our Planet & Peop

December 28, 2020 EX-99.(I)(2)

Opinion of Morris, Nichols, Arsht & Tunnell LLP. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (i)(2) [Letterhead of Morris, Nichols, Arsht & Tunnell LLP] December 28, 2020 Gabelli ETFs Trust One Corporate Center Rye, New York 10580-1422 Re: Gabelli ETFs Trust Ladies and Gentlemen: We have acted as special Delaware counsel to Gabelli ETFs Trust, a Delaware statutory trust (the “Trust”), in connection with certain matters of Delaware law relating to the issuance of Shares of Gabelli Growth Innovators ETF, Gabelli Financial Services ETF, Gabelli Global Small Cap ETF, Gabelli Small & Mid Cap ETF, Gabelli Micro Cap ETF, Gabelli Love Our Planet & People ETF, Gabelli Asset ETF, Gabelli Equity Income ETF and Gabelli Green Energy ETF, each a Series of the Trust (the “Registered Shares”).

December 28, 2020 EX-99.(D)(4)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Small & Mid Cap

EX-99.(D)(4) 8 ex-d4.htm INVESTMENT ADVISORY AGREEMENT BETWEEN THE REGISTRANT AND GABELLI FUNDS, LLC, ON BEHALF OF GABELLI SMALL AND MID CAP ETF GABELLI ETFs TRUST N-1A/A Exhibit (d)(4) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Small & Mid Cap ETF (the “Trust” and the “Fund”, respectiv

December 28, 2020 EX-99.(D)(1)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Growth Innovators ETF. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (d)(1) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Growth Innovators ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 EX-99.(A)

Amended and Restated Declaration of Trust for Gabelli ETFs Trust (the “Registrant”). (2)

GABELLI ETFs TRUST N-1A/A Exhibit (a) GABELLI ETFS TRUST AMENDED AND RESTATED DECLARATION OF TRUST Dated: [ ], 2020 TABLE OF CONTENTS Page ARTICLE I NAME, PURPOSE AND DEFINITIONS 1 Section 1.

December 28, 2020 EX-99.(I)(1)

Consent of Paul Hastings, LLP.

Exhibit (i)(1) CONSENT OF COUNSEL We consent to the reference to our Firm under the heading “Counsel” in the Registration Statement on Form N-1A/A of Gabelli ETFs Trust as filed with the Securities and Exchange Commission on or about December 28, 2020. /s/ Paul Hastings LLP PAUL HASTINGS LLP New York, New York December 28, 2020

December 28, 2020 EX-99.(D)(9)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Green Energy ETF.

GABELLI ETFs TRUST N-1A/A Exhibit (d)(9) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Green Energy ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 28, 2020 EX-99.(B)

By-Laws of the Registrant. (2)

EX-99.(B) 4 ex-b.htm BY-LAWS GABELLI ETFs TRUST N-1A/A Exhibit (b) Gabelli ETFS trust BY-LAWS Dated as of [ ], 2020 table of contents Page ARTICLE I Shareholder Meetings 1 1.1 Chairperson 1 1.2 Inspectors of Election 1 1.3 Inspection of Records 1 ARTICLE II Trustees 1 2.1 Annual and Regular Meetings 1 2.2 Chairperson 1 ARTICLE III Officers 2 3.1 Officers of the Trust 2 3.2 Election and Tenure 2 3.

December 28, 2020 N-1A/A

As filed with the Securities and Exchange Commission on December 28, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A

Securities Act File No. 333-238109 Investment Company Act File No. 812-15036 As filed with the Securities and Exchange Commission on December 28, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. 2 ☐ Post-Effective Amendment No. and/or REGISTRATION STATEMENT UNDER THE INVESTME

December 28, 2020 RW WD

- WITHDRAWAL OF A REGISTRATION WITHDRAWAL REQUEST

(212) 318-6736 [email protected] December 28, 2020 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A 1933 Act /1940 Act File No. 333-249489 / 812-15036 Ladies and Gentlemen: I am writing on behalf of the above-referenced Registrant, to respectfully request the withdrawal, eff

December 28, 2020 EX-99.(D)(2)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Financial Services ETF. (2)

GABELLI ETFs TRUST N-1A/A Exhibit (d)(2) INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Financial Services ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

December 14, 2020 CORRESP

-

(212) 318-6054 [email protected] December 14, 2020 Mr. Jeffrey A. Foor U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the ?Trust?) File Numbers: 333-238109; 811-23568 Dear Mr. Foor: This letter responds to additional comments provided by the staff of the Division of Investment Management (the ?

October 20, 2020 EX-99.(J)(2)

Powers of Attorney for Christopher J. Marangi, John Birch, Anthony S. Colavita, Leslie F. Foley, Michael Ferrantino, Michael J. Melarkey, Kuni Nakamura, and Salvatore J. Zizza, dated October 14, 2020. (1)

Powers of Attorney POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that each person whose name appears below nominates, constitutes and appoints John C.

October 20, 2020 EX-99.(D)(2)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Financial Services ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Financial Services ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 20, 2020 EX-99.(D)(3)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Global Small Cap ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Global Small Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 20, 2020 EX-99.(D)(6)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Love Our Planet & People ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Love Our Planet & People ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 20, 2020 EX-99.(H)(3)

Authorized Participant Agreement between G.distributors, LLC and the Authorized Participant named therein. (1)

FORM OF AUTHORIZED PARTICIPANT AGREEMENT GABELLI ETFS TRUST This Authorized Participant Agreement (the “Agreement”) is entered into by and between G.

October 20, 2020 EX-99.(E)(1)

Distribution Agreement between the Registrant and G.distributors, LLC. (1)

Distribution Agreement between the Registrant and G.distributors, LLC. DISTRIBUTION AGREEMENT FOR THE GABELLI ETFS TRUST Distribution Agreement (the “Agreement”), dated [ ], 2020 between the Gabelli ETFs Trust, a Delaware statutory trust (the “Trust”), and G.distributors, LLC, a Delaware limited liability company (the “Distributor”). WHEREAS, the Trust is a registered open-end management investmen

October 20, 2020 COVER

October 20, 2020

1(212) 318-6736 [email protected] October 20, 2020 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A 1940 Act File No. 812-15036 Ladies and Gentlemen: On behalf of the Registrant, we hereby transmit for filing, pursuant to the Securities Act of 1933, as amended, and under the

October 20, 2020 N-1A/A

As filed with the Securities and Exchange Commission on October 20, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. 1 ☐ Post-

GABELLI ETFs TRUST Securities Act File No. 333-238109 Investment Company Act File No. 812-15036 As filed with the Securities and Exchange Commission on October 20, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. 1 ☐ Post-Effective Amendment No. and/or REGISTRATION STATEMENT

October 20, 2020 EX-99.(H)(2)

Amendment to Sub-Administration and Accounting Agreement between the Registrant and The Bank of New York Mellon. (1)

Amendment to Sub-Administration and Accounting Agreement. AMENDMENT TO SUB-ADMINISTRATION AND ACCOUNTING AGREEMENT This Amendment (the “Amendment”) is made as of , 2020 by and between GABELLI FUNDS LLC (the “Administrator”) with respect to each investment company referenced on Exhibit A hereto (each, a “Fund”, collectively, the “Funds”) and THE BANK OF NEW YORK MELLON (as assigned from BNY Mellon

October 20, 2020 EX-99.(H)(1)

Transfer Agency and Service Agreement between the Registrant and The Bank of New York Mellon. (1)

Transfer Agency and Service Agreement between the Registrant and The BNY Mellon. TRANSFER AGENCY AND SERVICE AGREEMENT THIS AGREEMENT is made as of the day of , 2020, by and between the GABELLI ETFs TRUST (the “Trust”) and THE BANK OF NEW YORK MELLON, a New York corporation authorized to do a banking business having its principal office and place of business at 240 Greenwich Street, New York, New

October 20, 2020 EX-99.(D)(4)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Small & Mid Cap ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Small & Mid Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 20, 2020 EX-99.(D)(9)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Green Energy ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Green Energy ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 20, 2020 EX-99.(G)(2)

Amendment to Foreign Custody Manager Agreement between GAMCO Investors, Inc. on behalf of the Registrant and The Bank of New York Mellon. (1)

Amendment to Foreign Custody Manager Agreement between GAMCO Investors, Inc. EXECUTION AMENDMENT TO FOREIGN CUSTODY MANAGER AGREEMENT This Amendment (“Amendment”) is made as of the day of , 2020, by and between GAMCO INVESTORS, INC. (the “Client”) for and on behalf of each entity listed on Annex I attached to the Agreement (as defined below) (each, a “Fund” and collectively, the “Funds”) and THE B

October 20, 2020 EX-99.(D)(1)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Growth Innovators ETF.+

EX-99.(D)(1) 2 d98712dex99d1.htm INVESTMENT ADVISORY AGREEMENT BETWEEN THE REGISTRANT AND GABELLI FUNDS, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Growth Innovators ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability

October 20, 2020 EX-99.(H)(4)

AP Representative Confidentiality Agreement between the Registrant and the AP Representative named therein. (1)

AP Representative Confidentiality Agreement ACTIVESHARES® ETFs AP REPRESENTATIVE CONFIDENTIALITY & UNDERTAKINGS AGREEMENT This AP Representative Confidentiality Agreement (this “Agreement”) is entered into by and among (“AP Representative”) and the Gabelli ETFs Trust (the “Trust”), an open-end management investment company registered with the Securities and Exchange Commission (the “SEC”) under the Investment Company Act of 1940, as amended (the “1940 Act”), on behalf of each of its separate series (each, a “Fund” and collectively, the “Funds”).

October 20, 2020 EX-99.(G)(1)

Custody Agreement between the Registrant and The Bank of New York Mellon. (1)

EXECUTION Appendix A THIS APPENDIX A, amended and restated as of , 2020, is the Appendix A to that certain Custody Agreement between GAMCO INVESTORS, INC.

October 20, 2020 EX-99.(D)(8)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Equity Income ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Equity Income ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 20, 2020 EX-99.(E)(2)

Plan of Distribution Pursuant to Rule 12b-1 of the Registrant. (1)

Plan of Distribution Pursuant to Rule 12b-1 of the Registrant. PLAN OF DISTRIBUTION PURSUANT TO RULE 12b-1 OF THE GABELLI ETFS TRUST WHEREAS, the Gabelli ETFs Trust (the “Trust”) is a registered investment company organized under the laws of the State of Delaware and is registered as such under the Investment Company Act of 1940, as amended (the “1940 Act”), and is authorized to issue separate ser

October 20, 2020 EX-99.(I)

Consent of Paul Hastings LLP, Trust Counsel.+

CONSENT OF COUNSEL We consent to the reference to our Firm under the heading “Counsel” to the Registration Statement on Form N-1A of Gabelli ETFs Trust as filed with the Securities and Exchange Commission on or about October 15, 2020 /s/ Paul Hastings LLP PAUL HASTINGS LLP New York, New York October 15, 2020

October 20, 2020 EX-99.(D)(10)

Fee Waiver Agreement between the Registrant and Gabelli Funds, LLC, on behalf the Gabelli Love Our Planet & People

GABELLI ETFS TRUST FEE WAIVER AGREEMENT THIS FEE WAIVER AGREEMENT (the “Agreement”) is effective as of the [ ] day of [ ], 2020, by and between Gabelli ETFs Trust, a Delaware statutory trust (the “Trust”), on behalf of its series, Gabelli Love Our Planet & People ETF (the “Fund”), and the investment adviser, Gabelli Funds, LLC (the “Adviser”).

October 20, 2020 EX-99.(D)(7)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Asset ETF.+

EX-99.(D)(7) 8 d98712dex99d7.htm INVESTMENT ADVISORY AGREEMENT BETWEEN THE REGISTRANT AND GABELLI FUNDS, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Asset ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company. In

October 20, 2020 EX-99.(D)(5)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Micro Cap ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Micro Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 16, 2020 RW

- GABELLI ETFS TRUST

Gabelli ETFs Trust 1(212) 318-6736 [email protected] October 16, 2020 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Registration Statement on Form N-1A/A Securities Act/Investment Company Act File No. 333-238109/ 812-15036 Ladies and Gentlemen: I am writing on behalf of the above-referenced Registrant, purs

October 15, 2020 EX-99.(D)(10)

Fee Waiver Agreement between the Registrant and Gabelli Funds, LLC, on behalf the Gabelli Love Our Planet & People ETF.+

EX-99.(D)(10) 11 d98712dex99d10.htm FEE WAIVER AGREEMENT BETWEEN THE REGISTRANT AND GABELLI FUNDS, LLC GABELLI ETFS TRUST FEE WAIVER AGREEMENT THIS FEE WAIVER AGREEMENT (the “Agreement”) is effective as of the [ ] day of [ ], 2020, by and between Gabelli ETFs Trust, a Delaware statutory trust (the “Trust”), on behalf of its series, Gabelli Love Our Planet & People ETF (the “Fund”), and the investm

October 15, 2020 EX-99.(D)(1)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Growth Innovators ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Growth Innovators ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(D)(3)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Global Small Cap ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Global Small Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(D)(6)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Love Our Planet & People ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Love Our Planet & People ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(H)(2)

Amendment to Sub-Administration and Accounting Agreement between the Registrant and The Bank of New York Mellon.+

Amendment to Sub-Administration and Accounting Agreement. AMENDMENT TO SUB-ADMINISTRATION AND ACCOUNTING AGREEMENT This Amendment (the “Amendment”) is made as of , 2020 by and between GABELLI FUNDS LLC (the “Administrator”) with respect to each investment company referenced on Exhibit A hereto (each, a “Fund”, collectively, the “Funds”) and THE BANK OF NEW YORK MELLON (as assigned from BNY Mellon

October 15, 2020 N-1A

- GABELLI ETFS TRUST

GABELLI ETFs TRUST Securities Act File No. 333-238109 Investment Company Act File No. 812-15036 As filed with the Securities and Exchange Commission on October 15, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. 1 ☐ Post-Effective Amendment No. and/or REGISTRATION STATEMENT

October 15, 2020 EX-99.(H)(3)

Authorized Participant Agreement between G.distributors, LLC and the Authorized Participant named therein.+

FORM OF AUTHORIZED PARTICIPANT AGREEMENT GABELLI ETFS TRUST This Authorized Participant Agreement (the “Agreement”) is entered into by and between G.

October 15, 2020 EX-99.(D)(5)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Micro Cap ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Micro Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(D)(7)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Asset ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Asset ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(G)(1)

Custody Agreement between the Registrant and The Bank of New York Mellon.+

Custody Agreement between the Registrant and The Bank of New York Mellon. EXECUTION Appendix A THIS APPENDIX A, amended and restated as of , 2020, is the Appendix A to that certain Custody Agreement between GAMCO INVESTORS, INC. and THE BANK OF NEW YORK MELLON dated June 10, 2008, as amended. Gabelli & Company, Inc. Gabelli Securities, Inc. Gabelli Trading Holdings, LLC GAMCO Asset Management Inc.

October 15, 2020 EX-99.(E)(2)

Plan of Distribution Pursuant to Rule 12b-1 of the Registrant.+

Plan of Distribution Pursuant to Rule 12b-1 of the Registrant. PLAN OF DISTRIBUTION PURSUANT TO RULE 12b-1 OF THE GABELLI ETFS TRUST WHEREAS, the Gabelli ETFs Trust (the “Trust”) is a registered investment company organized under the laws of the State of Delaware and is registered as such under the Investment Company Act of 1940, as amended (the “1940 Act”), and is authorized to issue separate ser

October 15, 2020 EX-99.(D)(2)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Financial Services ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Financial Services ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(I)

Consent of Paul Hastings LLP, Trust Counsel.+

Consent of Paul Hastings, LLP. CONSENT OF COUNSEL We consent to the reference to our Firm under the heading “Counsel” to the Registration Statement on Form N-1A of Gabelli ETFs Trust as filed with the Securities and Exchange Commission on or about October 15, 2020 /s/ Paul Hastings LLP PAUL HASTINGS LLP New York, New York October 15, 2020

October 15, 2020 EX-99.(J)(2)

Powers of Attorney for Christopher J. Marangi, John Birch, Anthony S. Colavita, Leslie F. Foley, Michael Ferrantino, Michael J. Melarkey, Kuni Nakamura, and Salvatore J. Zizza, dated October 14, 2020.+

EX-99.(J)(2) 21 d98712dex99j2.htm POWERS OF ATTORNEY POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that each person whose name appears below nominates, constitutes and appoints John C. Ball and Peter Goldstein (with full power to each of them to act alone) his true and lawful attorney-in-fact and agent, for him and on his behalf and in his place and stead in any and all capacities, to make, ex

October 15, 2020 CORRESP

-

(212) 318-6736 [email protected] October 15, 2020 Mr. Jeffrey A. Foor U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the ?Trust?) File Numbers: 333-238109; 811-23568 Dear Mr. Foor: This letter responds to written comments provided by the staff of the Division of Investment Management (the ?Staff?)

October 15, 2020 EX-99.(D)(8)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Equity Income ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Equity Income ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(H)(4)

AP Representative Confidentiality Agreement between the Registrant and the AP Representative named therein.+

ACTIVESHARES® ETFs AP REPRESENTATIVE CONFIDENTIALITY & UNDERTAKINGS AGREEMENT This AP Representative Confidentiality Agreement (this “Agreement”) is entered into by and among (“AP Representative”) and the Gabelli ETFs Trust (the “Trust”), an open-end management investment company registered with the Securities and Exchange Commission (the “SEC”) under the Investment Company Act of 1940, as amended (the “1940 Act”), on behalf of each of its separate series (each, a “Fund” and collectively, the “Funds”).

October 15, 2020 EX-99.(D)(9)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Green Energy ETF.+

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Green Energy ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

October 15, 2020 EX-99.(E)(1)

Distribution Agreement between the Registrant and G.distributors, LLC.+

DISTRIBUTION AGREEMENT FOR THE GABELLI ETFS TRUST Distribution Agreement (the “Agreement”), dated [ ], 2020 between the Gabelli ETFs Trust, a Delaware statutory trust (the “Trust”), and G.

October 15, 2020 EX-99.(H)(1)

Transfer Agency and Service Agreement between the Registrant and The Bank of New York Mellon.+

Transfer Agency and Service Agreement between the Registrant and The BNY Mellon. TRANSFER AGENCY AND SERVICE AGREEMENT THIS AGREEMENT is made as of the day of , 2020, by and between the GABELLI ETFs TRUST (the “Trust”) and THE BANK OF NEW YORK MELLON, a New York corporation authorized to do a banking business having its principal office and place of business at 240 Greenwich Street, New York, New

October 15, 2020 EX-99.(G)(2)

Amendment to Foreign Custody Manager Agreement between GAMCO Investors, Inc. on behalf of the Registrant and The Bank of New York Mellon.+

Amendment to Foreign Custody Manager Agreement between GAMCO Investors, Inc. EXECUTION AMENDMENT TO FOREIGN CUSTODY MANAGER AGREEMENT This Amendment (“Amendment”) is made as of the day of , 2020, by and between GAMCO INVESTORS, INC. (the “Client”) for and on behalf of each entity listed on Annex I attached to the Agreement (as defined below) (each, a “Fund” and collectively, the “Funds”) and THE B

October 15, 2020 EX-99.(D)(4)

Investment Advisory Agreement between the Registrant and Gabelli Funds, LLC, on behalf of Gabelli Small & Mid Cap ETF.+

INVESTMENT ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT, dated , 2020, between The Gabelli ETFs Trust, a Delaware statutory trust, on behalf of Gabelli Small & Mid Cap ETF (the “Trust” and the “Fund”, respectively), and Gabelli Funds, LLC (the “Adviser”), a New York limited liability company.

May 8, 2020 EX-99.(I)

Consent of Paul Hastings LLP, Trust Counsel.+

CONSENT OF COUNSEL We consent to the reference to our Firm under the heading “Counsel” to the Registration Statement on Form N-1A of Gabelli ETFs Trust as filed with the Securities and Exchange Commission on or about May 8, 2020. /s/ Paul Hastings LLP PAUL HASTINGS LLP New York, New York May 8, 2020

May 8, 2020 COVER

May 8, 2020

1(212) 318-6736 [email protected] May 8, 2020 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Gabelli ETFs Trust (the “Registrant”) Initial Registration Statement on Form N-1A 1940 Act File No. 811-23568 Ladies and Gentlemen: On behalf of the Registrant, we hereby transmit for filing, pursuant to the Securities Act of 1933, as amended, and under

May 8, 2020 N-1A

As filed with the Securities and Exchange Commission on May 8, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. ☐ Post-Effecti

GABELLI ETFs TRUST Table of Contents Securities Act File No. [•] Investment Company Act File No. 811-23568 As filed with the Securities and Exchange Commission on May 8, 2020 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. ☐ Post-Effective Amendment No. and/or REGISTRATION STATEM

May 8, 2020 N-8A

- GABELLI ETFS TRUST

Gabelli ETFs Trust UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

May 8, 2020 EX-99.(A)

Amended and Restated Declaration of Trust for Gabelli ETFs Trust (the “Registrant”), dated May 5, 2020.+

Amended and Restated Declaration of Trust of the Registrant AMENDED AND RESTATED DECLARATION OF TRUST, dated as of May 5, 2020, by the individual trustee identified on the signature page hereto (the “Trustee”) and acknowledged and agreed by the other individual identified on the signature page hereto.

April 30, 2019 APP WD

1(212) 318-6054

1(212) 318-6054 [email protected] April 30, 2019 VIA EDGAR Ms. Erin Loomis U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Gabelli ETFs Trust (the ?Trust?) File No. 812-14935 Dear Ms. Loomis: On July 31, 2018, the Trust, Gabelli Funds, LLC (the ?Adviser?), and G.distributors, LLC (the ?Distributor,? and together

Fintel data has been cited in the following publications:
Daily Mail Fox Business Business Insider Wall Street Journal The Washington Post Bloomberg Financial Times Globe and Mail
NASDAQ.com Reuters The Guardian Associated Press FactCheck.org Snopes Politifact
Federal Register The Intercept Forbes Fortune Magazine TheStreet Time Magazine Canadian Broadcasting Corporation International Business Times
Cambridge University Press Investopedia MarketWatch NY Daily News Entrepreneur Newsweek Barron's El Economista