Re: Request for Comment on Novel Exchange-Traded Products To the Commission: Thank you for the opportunity to comment on the Commission's request for comment on novel exchange‑traded products. I appreciate the Commission's efforts to bring greater consistency, transparency, and predictability to the review of ETF/ETP filings. My comments focus on three areas where clearer standards would benefit both sponsors and investors. 1. Well-established fund groups should be able to bring new series to market without delay In the operating company space, well-known seasoned issuers are permitted to go effective immediately when offering new securities. A similar framework should exist for large, well‑established fund groups that have long track records of compliant operations, robust disclosure controls, and mature compliance programs. When such a sponsor seeks to launch a new series that fits within its existing registration framework, the filing should be permitted to go effective upon submission. This approach would reduce unnecessary delays, allow sponsors to respond to market developments more efficiently, and free Commission staff to focus on genuinely novel or higher-risk products. Investors benefit when established sponsors can bring straightforward products to market without extended review periods. 2. Legal objections or structural concerns should be made public if they are used to delay effectiveness If a sponsor objects to a particular structure or asserts a legal conclusion that it believes should govern the treatment of a product, that conclusion should be made public. Transparency ensures that all market participants can understand the basis for the objection and evaluate whether it has broader implications. Similarly, if the Commission relies on a legal interpretation or structural concern to delay a series from going effective, that interpretation should be published. If the Commission is not prepared to stand behind the interpretation in writing, then it should not be used to hold up a filing. Public articulation of the reasoning promotes fairness, consistency, and predictability across sponsors. 3. All ETPs, including those registered only under the Securities Act, should be on Form N-1A The Commission should place all ETPs, including those registered solely under the Securities Act, on Form N-1A and apply a consistent filing framework. Today's split regime creates confusion for investors and inefficiencies for sponsors. A unified form would simplify disclosure, reduce duplicative requirements, and ensure that similar products are reviewed under similar standards. A single framework would also help new Commission attorneys and reviewers by providing one coherent set of rules rather than multiple regimes that vary based on historical distinctions rather than investor needs. Conclusion These changes would promote clarity, fairness, and efficiency in the review of ETF/ETP filings. They would also help ensure that investors receive consistent disclosures and that sponsors operate within a predictable regulatory environment. I appreciate the Commission's attention to these issues and encourage it to adopt a framework that reflects the maturity and importance of the ETP market.