Subject: File No. S7-2026-24
From: Lina Druker

The SEC should not allow ETFs to use obscure structures like SPVs. SPVs are all over the press these days as being opaque and not providing the results that are expected. ETFs are required to disclose their holdings daily. Pointing to an SPV, where you cannot see what it holds, does not provide sufficient transparency for an arbitrage mechanism to work effectively. For example, several ETFs held SpaceX in an SPV (e.g., XOVR) and the SPV name in the ETFs holdings suggested the SPV was all about SpaceX. However, the value of the SPV did not appear to move with SpaceX nor have meaningful economic exposure to SpaceX. This is a problem and likely outright fraud. The ETF mislead investors. ETFs should be required to look through structures such as SPVs and subsidiaries and show the true holdings of the ETF.