Persistence Analytics Group LLC respectfully submits this comment in response to the Securities and Exchange Commission's request for public comment on novel exchange"-traded funds. The Commission's request is timely because the ETF wrapper is increasingly being used to package exposures that may be difficult for investors to understand, verify, or stress"-test. Novel ETFs may provide access to innovative strategies, but innovation should not obscure the assumptions that drive return, loss, liquidity, compounding behavior, path dependency, volatility, and failure modes. The core investor"-protection question is not only whether a novel ETF can be listed. It is whether the assumptions inside the product are sufficiently transparent, understandable, and verifiable for the intended investor base. A novel ETF may appear simple because it trades on an exchange. But the underlying exposure may depend on assumptions involving: leverage behavior; daily reset mechanics; path dependency; volatility drag; options"-income durability; single"-stock concentration; crypto"-market structure; event"-outcome mechanics; counterparty exposure; liquidity under stress; valuation transparency; retail suitability; and operational resilience. The wrapper may be liquid. The assumptions underneath may not be. For that reason, the Commission should consider whether novel ETFs should be evaluated not only through traditional disclosure and listing standards, but also through an assumption"-verification lens. A practical framework could ask: 1. What assumptions drive the product's expected return? 2. What assumptions drive the product's expected loss? 3. How does the product behave under stress? 4. Does the product contain path dependency that may not be intuitive to investors? 5. Does the product rely on market liquidity that may disappear during volatility? 6. Are retail investors likely to understand the difference between the exposure advertised and the exposure actually delivered? 7. Are compounding, reset, leverage, options, derivative, or event"-linked mechanics explained in plain language? 8. Can investors understand what would cause the product to fail, deviate, suspend, liquidate, or produce materially different outcomes from expectations? 9. Are market makers, authorized participants, counterparties, custodians, and pricing sources resilient under stress? 10. Does the product create risks that are better understood by the sponsor than by the investor? The Commission should also consider whether novel ETFs need clearer disclosure around the "risk engine" of the product. Investors should not only know the asset class or theme. They should understand what actually determines performance. For example, an investor in a thematic ETF may believe they are buying exposure to a broad economic trend. But the product's actual performance may depend on concentration, index methodology, liquidity, valuation, supply"-chain assumptions, regulatory exposure, financing conditions, or infrastructure constraints. Similarly, an investor in a leveraged, options"-based, crypto"-linked, single"-stock, or event"-linked ETF may believe they are buying a simple directional exposure. In reality, the product may depend on timing, volatility, compounding effects, derivative pricing, counterparty performance, or market structure dynamics that are not visible from the fund name alone. This creates a disclosure problem and an assumption"-integrity problem. Persistence Analytics Group LLC focuses on assumption verification, decision"-grade evidence, infrastructure risk, public"-cost exposure, energy systems, AI/data"-center exposure, and capital"-market risk. Across those areas, the same principle applies: When capital is allocated around assumptions that are not fully tested, risk can become mispriced. Novel ETFs raise a similar concern in the investment"-product context. The Commission should consider whether sponsors of novel ETFs should be expected to provide plain"-language answers to several investor"-facing questions: What is the product designed to do? What must be true for it to work? What assumptions could fail? Who bears the loss if they fail? How does the product behave in stress? How could outcomes differ from investor expectations? How is the exposure verified? These questions would not prohibit innovation. They would strengthen it by making novel products more transparent, more understandable, and more defensible. The goal should not be to prevent new ETF structures from reaching the market. The goal should be to ensure that when they do, investors can understand and verify the exposure they are buying. Simple principle: Trust the wrapper. Verify the exposure. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity neil@persistenceanalyticsgroup.com 609"-464"-9055 https : / / persistenceanalyticsgroup . com / SAM . gov Registered Vendor UEI: D3VYU39H6DX9 | CAGE: 19T34 D"-U"-N"-S: 142849930