| | |
| ☐ |
immediately upon filing pursuant to paragraph (b) |
| ☒ |
on April 30, 2026 pursuant to paragraph (b) |
| ☐ |
60 days after filing pursuant to paragraph (a) |
| ☐ |
on (date) pursuant to paragraph (a) |
| ☐ |
75 days after filing pursuant to paragraph (a)(2) |
| ☐ |
on (date) pursuant to paragraph (a)(2) of rule 485. If appropriate, check the following box: |
| ☐ |
This post-effective amendment designates a new effective date for a previously filed post-effective amendment |
| |
Ticker Symbol |
|
Principal U.S. Listing Exchange |
| Touchstone Dividend Select ETF |
DVND |
|
NYSE Arca, Inc. |
| Touchstone Dynamic International ETF |
TDI |
|
The Nasdaq Stock Market LLC |
| Touchstone International Equity ETF |
TLCI |
|
NYSE Arca, Inc. |
| Touchstone Large Company Growth ETF |
TLG |
|
The Nasdaq Stock Market LLC |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF |
TEMX |
|
Cboe BZX Exchange, Inc. |
| Touchstone Sands Capital US Select Growth ETF |
TSEL |
|
The Nasdaq Stock Market LLC |
| Touchstone Securitized Income ETF |
TSEC |
|
NYSE Arca, Inc. |
| Touchstone Strategic Income ETF |
SIO |
|
NYSE Arca, Inc. |
| Touchstone Ultra Short Income ETF |
TUSI |
|
Cboe BZX Exchange, Inc. |
| Touchstone US Large Cap Focused ETF |
LCF |
|
Cboe BZX Exchange, Inc. |
| |
Touchstone Dividend Select ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Acquired Fund Fees and Expenses (AFFE) |
|
| Total Annual Fund Operating Expenses(2) |
|
| Fee Waiver and/or Expense Reimbursement(3) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2)(3) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
|
Since Inception |
| |
1 Year |
|
| Touchstone Dividend Select ETF |
|
|
| Return Before Taxes |
% |
% |
| Return After Taxes on Distributions |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
| Bloomberg US 3000 Index(1) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Bloomberg US 1000 Value Index(2) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Russell 3000® Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Russell 1000® Value Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Fort Washington Investment Advisors, Inc. |
Austin R. Kummer, CFA |
Since inception in August 2022 |
Managing Director, Senior Portfolio Manager |
| |
James E. Wilhelm, Jr. |
Since inception in August 2022 |
Managing Director, Senior Portfolio Manager |
| |
Touchstone Dynamic International ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Total Annual Fund Operating Expenses |
|
| Fee Waiver and/or Expense Reimbursement(2) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
1 Year |
5 Years |
10 Years |
| Touchstone Dynamic International ETF |
|
|
|
| Return Before Taxes(1) |
% |
% |
% |
| Return After Taxes on Distributions |
% |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
% |
| Bloomberg World ex US Large & Mid Cap Index(2) (reflects no deduction for fees, expenses or taxes, except foreign withholding taxes on dividends) |
% |
% |
% |
| MSCI All Country World Ex USA Index (reflects no deduction for fees, expenses or taxes, except foreign withholding taxes on dividends) |
% |
% |
% |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Los Angeles Capital Management LLC |
Hal W. Reynolds, CFA |
Since inception in December 2023 |
Vice Chairman |
| |
Ed Rackham, Ph.D. |
Since inception in December 2023 |
Chief Investment Officer |
| |
Daniel Arche, CFA |
Since inception in December 2023 |
Senior Portfolio Manager |
| |
Touchstone International Equity ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Total Annual Fund Operating Expenses |
|
| Fee Waiver and/or Expense Reimbursement(2) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| Sub-Adviser |
Portfolio Manager |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| London Company of Virginia d/b/a/ The London Company |
TJ Carter, CFA, CPA |
Since inception in March 2025 |
Portfolio Manager |
| |
Touchstone Large Company Growth ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses(2) |
|
| Total Annual Fund Operating Expenses |
|
| Fee Waiver and/or Expense Reimbursement(3) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(3) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
1 Year |
5 Years |
10 Years |
| Predecessor Fund - Touchstone Large Company Growth ETF |
|
|
|
| Return Before Taxes |
% |
% |
% |
| Return After Taxes on Distributions |
% |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
% |
| Bloomberg US 3000 Index(1) (reflects no deduction for fees, expenses or taxes) |
% |
% |
% |
| Bloomberg US 1000 Growth Index(2) (reflects no deduction for fees, expenses or taxes) |
% |
% |
% |
| Russell 3000® Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
% |
| Russell 1000® Growth Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
% |
| Sub- Adviser |
Portfolio Manager |
Investment Experience with the Fund and the Predecessor Fund |
Primary Title with Sub-Adviser |
| DSM Capital Partners LLC |
Daniel Strickberger |
Since inception in March, 2026; managed the Predecessor Fund from 2016 to 2026 |
Chief Investment Officer and Managing Partner |
| |
David McVey |
Since inception in March, 2026; managed the Predecessor Fund from 2020 to 2026 |
Deputy Chief Investment Officer and Portfolio Manager |
| |
Eric Woodworth, CFA |
Since inception in March, 2026; managed the Predecessor Fund from 2021 to 2026 |
Deputy Chief Investment Officer and Portfolio Manager |
| |
Touchstone Sands Capital Emerging Markets ex-China Growth ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Acquired Fund Fees and Expenses (AFFE) |
|
| Total Annual Fund Operating Expenses(2) |
|
| Fee Waiver and/or Expense Reimbursement(3) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2)(3) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Sands Capital Management, LLC |
Brian A. Christiansen, CFA |
Since inception in February 2025 |
Sr. Portfolio Manager, Research Analyst, Executive Managing Director |
| |
Teeja Boye, CFA |
Since inception in February 2025 |
Portfolio Manager and Sr. Research Analyst |
| |
Touchstone Sands Capital US Select Growth ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Total Annual Fund Operating Expenses |
|
| Fee Waiver and/or Expense Reimbursement(2) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
|
Since Inception |
| |
1 Year |
|
| Touchstone Sands Capital US Select Growth ETF |
|
|
| Return Before Taxes |
% |
% |
| Return After Taxes on Distributions |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
| Bloomberg US 3000 Index(1) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Bloomberg US 1000 Growth Index(2) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Russell 3000® Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Russell 1000® Growth Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Sands Capital Management, LLC |
Wesley A. Johnston, CFA |
Since inception in January 2025 |
Sr. Portfolio Manager, Research Analyst |
| |
Thomas H. Trentman, CFA |
Since inception in January 2025 |
Sr. Portfolio Manager, Research Analyst |
| |
Benjamin H. Betcher |
Since January 2026 |
Portfolio Manager and Senior Research Analyst |
| |
Touchstone Securitized Income ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Acquired Fund Fees and Expenses (AFFE) |
|
| Total Annual Fund Operating Expenses(2) |
|
| Fee Waiver and/or Expense Reimbursement(3) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2)(3) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
|
Since Inception |
| |
1 Year |
|
| Touchstone Securitized Income ETF |
|
|
| Return Before Taxes |
% |
% |
| Return After Taxes on Distributions |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
| Bloomberg US Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Fort Washington Investment Advisors, Inc. |
Scott D. Weston |
Since inception in July 2023 |
Managing Director and Senior Portfolio Manager |
| |
Brent A. Miller, CFA |
Since inception in July 2023 |
Vice President and Senior Portfolio Manager |
| |
Laura L. Mayfield |
Since inception in July 2023 |
Assistant Vice President and Senior Portfolio Manager |
| |
Richard Schneider |
Since inception in July 2023 |
Vice President and Senior Portfolio Manager |
| |
Touchstone Strategic Income ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Acquired Fund Fees and Expenses (AFFE) |
|
| Total Annual Fund Operating Expenses(2) |
|
| Fee Waiver and/or Expense Reimbursement(3) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2)(3) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
|
Since Inception |
| |
1 Year |
|
| Touchstone Strategic Income ETF |
|
|
| Return Before Taxes |
% |
% |
| Return After Taxes on Distributions |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
| Bloomberg US Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Fort Washington Investment Advisors, Inc. |
Daniel J. Carter, CFA |
Since inception in July 2022 |
Managing Director and Senior Portfolio Manager |
| |
Austin R. Kummer, CFA |
Since inception in July 2022 |
Managing Director, Senior Portfolio Manager |
| |
Brendan M. White, CFA |
Since inception in July 2022 |
Senior Vice President, Co-Chief Investment Officer and Portfolio Manager |
| |
Touchstone Ultra Short Income ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Total Annual Fund Operating Expenses |
|
| Fee Waiver and/or Expense Reimbursement(2) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
|
Since Inception |
| |
1 Year |
|
| Touchstone Ultra Short Income ETF |
|
|
| Return Before Taxes |
% |
% |
| Return After Taxes on Distributions |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
| Bloomberg US Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Bloomberg US Treasury Bellwether 3 Month Index(1) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Bloomberg US Treasury Bellwether 1 Year Index(1) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| ICE BofA 3-Month U.S. Treasury Bill Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| ICE BofA 1-Year U.S. Treasury Note Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Fort Washington Investment Advisors, Inc. |
Scott D. Weston |
Since inception in August 2022 |
Managing Director and Senior Portfolio Manager |
| |
Brent A. Miller, CFA |
Since inception in August 2022 |
Vice President and Senior Portfolio Manager |
| Sub-Adviser |
Portfolio Managers |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| |
Laura L. Mayfield |
Since inception in August 2022 |
Assistant Vice President and Senior Portfolio Manager |
| |
Richard V. Schneider |
Since April 2023 |
Vice President and Senior Portfolio Manager |
| |
Touchstone US Large Cap Focused ETF |
| |
|
| Management Fees |
|
| Distribution and/or Shareholder Service (12b-1) Fees(1) |
|
| Other Expenses |
|
| Acquired Fund Fees and Expenses (AFFE) |
|
| Total Annual Fund Operating Expenses(2) |
|
| Fee Waiver and/or Expense Reimbursement(3) |
( |
| Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement(2)(3) |
|
| | |
| 1 Year |
$ |
| 3 Years |
$ |
| 5 Years |
$ |
| 10 Years |
$ |
| | ||
| |
|
% |
| |
|
% |
| |
|
% |
| |
|
Since Inception |
| |
1 Year |
|
| Touchstone US Large Cap Focused ETF |
|
|
| Return Before Taxes |
% |
% |
| Return After Taxes on Distributions |
% |
% |
| Return After Taxes on Distributions and Sale of Fund Shares |
% |
% |
| Bloomberg US 3000 Index(1) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Bloomberg US 1000 Index(2) (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Russell 3000® Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Russell 1000® Index (reflects no deduction for fees, expenses or taxes) |
% |
% |
| Sub-Adviser |
Portfolio Manager |
Investment Experience with the Fund |
Primary Title with Sub-Adviser |
| Fort Washington Investment Advisors, Inc. |
James E. Wilhelm, Jr. |
Since inception in July 2022 |
Managing Director & Senior Portfolio Manager |
| Sunit Gogia |
Since October 2024 |
Vice President, Portfolio Manager and Director of Equity Research |
| |
Dividend Select ETF |
Dynamic International ETF |
International Equity ETF |
Large Company Growth ETF |
Sands Capital Emerging Markets ex-China Growth ETF |
Sands Capital US Select Growth ETF |
Securitized Income ETF |
Strategic Income ETF |
Ultra Short Income ETF |
US Large Cap Focused ETF |
| Asset-Backed Securities Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Authorized Participants Concentration Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Cash and Cash Equivalents Risk |
X |
|
|
|
|
|
|
|
|
X |
| Collateralized Loan Obligations Risk |
|
|
|
|
|
|
X |
|
X |
|
| Counterparty Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Convertible Securities Risk |
|
|
|
X |
|
|
|
|
|
|
| Credit Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Cybersecurity Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Depositary Receipt Risk |
|
X |
X |
X |
X |
|
|
|
|
|
| Derivatives Risk |
|
|
|
|
|
|
|
X |
|
|
| Dividend Risk |
X |
|
|
|
|
|
|
|
|
|
| Economic and Market Events Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Emerging Markets Risk |
|
X |
X |
X |
X |
|
|
X |
|
|
| Equity-Related Securities Risk |
|
|
|
|
X |
|
|
|
|
|
| Equity Securities Risk |
X |
X |
X |
X |
X |
X |
|
X |
|
X |
| ESG Investing Risk |
|
|
|
|
X |
X |
|
|
|
|
| ETF Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Fixed-Income Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Foreign Securities Risk |
|
X |
X |
X |
X |
X |
|
X |
X |
|
| Forward Foreign Currency Exchange Contract Risk |
|
|
|
|
|
|
|
X |
|
|
| Frontier Markets Risk |
|
|
|
|
X |
|
|
|
|
|
| Futures Contracts Risk |
|
|
|
|
|
|
|
X |
|
|
| Growth-Investing Risk |
|
|
|
X |
X |
X |
|
|
|
|
| India Risk |
|
|
|
|
X |
|
|
|
|
|
| Interest Rate Risk |
|
|
|
|
|
|
X |
X |
X |
|
| |
Dividend Select ETF |
Dynamic International ETF |
International Equity ETF |
Large Company Growth ETF |
Sands Capital Emerging Markets ex-China Growth ETF |
Sands Capital US Select Growth ETF |
Securitized Income ETF |
Strategic Income ETF |
Ultra Short Income ETF |
US Large Cap Focused ETF |
| Investment-Grade Debt Securities Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Large-Cap Risk |
X |
|
X |
X |
X |
X |
|
|
|
X |
| Leverage Risk |
|
|
|
|
|
|
|
X |
|
|
| Management Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Mid-Cap Risk |
|
|
|
|
X |
X |
|
|
|
X |
| Mortgage-Backed Securities Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Mortgage Dollar Roll Risk |
|
|
|
|
|
|
|
X |
|
|
| Municipal Securities Risk |
|
|
|
|
|
|
X |
|
X |
|
| Non-Diversification Risk |
|
|
|
X |
X |
X |
|
|
|
X |
| Non-Investment-Grade Debt Securities Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Options Risk |
|
|
|
|
|
|
|
X |
|
|
| Other Investment Companies Risk |
|
X |
|
|
|
|
|
|
|
|
| Portfolio Turnover Risk |
|
X |
|
|
|
|
|
X |
X |
|
| Preferred Stock Risk |
|
X |
|
X |
X |
|
|
X |
|
|
| Premium/Discount Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Prepayment Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Quantitative Strategy Risk |
|
X |
|
|
|
|
|
|
|
|
| REIT Risk |
|
X |
|
|
|
|
|
|
|
|
| Repurchase Agreement Risk |
|
|
|
|
|
|
X |
|
X |
|
| Reverse Repurchase Agreement Risk |
|
|
|
|
|
|
|
X |
|
|
| Secondary Market Trading Risk |
X |
X |
X |
X |
X |
X |
X |
X |
X |
X |
| Sector and Industry Focus Risk |
|
|
|
X |
X |
|
|
|
|
X |
| Sector Focus Risk |
|
|
X |
|
|
X |
|
|
|
|
| Small-Cap Risk |
|
|
|
|
X |
|
|
|
|
|
| Sovereign Debt Risk |
|
|
|
|
|
|
|
X |
|
|
| Swap Agreement Risk |
|
|
|
|
|
|
|
X |
|
|
| U.S. Government Securities Risk |
|
|
|
|
|
|
X |
X |
X |
|
| Value Investing Risk |
X |
|
|
|
|
|
|
|
|
|
| Fund |
Net Annual Fee Rate as a % of average daily net assets(1) |
| Dividend Select ETF |
0.04% |
| Dynamic International ETF |
0.29% |
| International Equity ETF |
0.10% |
| Sands Capital Emerging Markets ex-China Growth ETF |
0.00% |
| Sands Capital US Select Growth ETF |
0.49% |
| Securitized Income ETF |
0.19% |
| Strategic Income ETF |
0.37% |
| Ultra Short Income ETF |
0.14% |
| Fund |
Net Annual Fee Rate as a % of average daily net assets(1) |
| US Large Cap Focused ETF |
0.21% |
| Fund |
Annual Investment Advisory Fee |
| Large Company Growth ETF(1) |
0.60% |
| |
1 Year |
Since Inception* |
| Fort Washington Dividend Select Equity Composite (Gross) |
16.59 % |
11.93 % |
| Fort Washington Dividend Select Equity Composite (Net) |
16.01 % |
11.37 % |
| Russell 1000® Value Index (reflects no deductions for fees, expenses or taxes) |
15.91 % |
9.86 % |
| |
1 Year |
5 Year |
10 Year |
Since Inception* |
| Fort Washington Securitized Composite (Gross) |
8.23 % |
4.04 % |
4.61 % |
6.12 % |
| Fort Washington Securitized Composite (Net) |
7.85 % |
3.68 % |
4.25 % |
5.75 % |
| Bloomberg US MBS Index (reflects no deductions for fees, expenses or taxes)** |
8.58 % |
0.15 % |
1.59 % |
1.78 % |
| Bloomberg US Aggregate Bond Index (reflects no deductions for fees, expenses or taxes)** |
7.30 % |
(0.36 %) |
2.01 % |
2.09 % |
| |
1 Year |
3 Years |
5 Years |
Since Inception* |
| Fort Washington Strategic Income Composite (Gross) |
9.75 % |
8.55 % |
3.55 % |
5.22 % |
| Fort Washington Strategic Income Composite (Net) |
9.31 % |
8.12 % |
3.13 % |
4.80 % |
| Bloomberg U.S. Aggregate Bond Index (reflects no deductions for fees, expenses or taxes) |
7.30 % |
4.66 % |
(0.36 )% |
1.78 % |
| |
1 Year |
Since Inception* |
| The London Company International Equity Strategy (Gross) |
17.6 % |
18.6 % |
| The London Company International Equity Strategy (Net) |
16.7 % |
17.7 % |
| MSCI EAFE Index (Net) (reflects no deductions for fees, expenses or taxes)** |
31.2 % |
19.9 % |
| |
1 Year |
Since Inception* |
| Sands Capital Emerging Markets ex-China Strategy (Gross) |
27.30 % |
18.04 % |
| Sands Capital Emerging Markets ex-China Strategy (Net) |
26.27 % |
17.07 % |
| MSCI Emerging Markets ex-China Index (reflects no deductions for fees, expenses or taxes)** |
34.61 % |
18.70 % |
| Fund |
Dividends Declared |
Dividends Paid |
| Dividend Select ETF |
Quarterly |
Quarterly |
| Dynamic International ETF |
Annually |
Annually |
| International Equity ETF |
Annually |
Annually |
| Large Company Growth ETF |
Annually |
Annually |
| Sands Capital Emerging Markets ex-China Growth ETF |
Annually |
Annually |
| Sands Capital US Select Growth ETF |
Annually |
Annually |
| Securitized Income ETF |
Monthly |
Monthly |
| Strategic Income ETF |
Monthly |
Monthly |
| US Large Cap Focused ETF |
Annually |
Annually |
| Ultra Short Income ETF |
Monthly |
Monthly |
| Touchstone Dividend Select ETF | |||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/22(1) |
$25.00 |
$0.18 |
$0.31 |
$0.49 |
$(0.18 ) |
$(0.18 ) |
$25.31 |
1.94 % (2) |
$26,570 |
0.67 % (3) |
1.41 % (3) |
2.11 %(3) |
28 % (2)(4) |
| 12/31/23 |
25.31 |
0.58 |
2.91 |
3.49 |
(0.58 ) |
(0.58 ) |
28.22 |
14.01 |
31,040 |
0.67 |
1.21 |
2.22 |
16 (4) |
| 12/31/24 |
28.22 |
0.64 |
2.62 |
3.26 |
(0.64 ) |
(0.64 ) |
30.84 |
11.59 |
33,929 |
0.64 |
1.16 |
2.11 |
13 (4) |
| 12/31/25 |
30.84 |
0.69 |
4.29 |
4.98 |
(0.68 ) |
(0.68 ) |
35.14 |
16.27 |
37,775 |
0.49 |
1.14 |
2.09 |
17 (4) |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (August 2, 2022) through December 31, 2022. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind and received from processing subscriptions-in-kind. |
| Touchstone Dynamic International ETF | ||||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Distributions from realized capital gains |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/21(1) |
$29.55 |
$0.46 |
$1.14 |
$1.60 |
$(0.82 ) |
$ (0.93 ) |
$(1.75 ) |
$29.40 |
5.39 % |
$5,061 |
0.24 % |
0.87 % |
1.51 % |
20 % |
| 12/31/22(1) |
29.40 |
0.44 |
(5.23 ) |
(4.79 ) |
(0.71 ) |
(0.62 ) |
(1.33 ) |
23.28 |
(16.34 ) |
2,987 |
0.24 |
0.99 |
1.75 |
60 |
| 12/31/23(1)(2) |
23.28 |
0.31 |
3.65 |
3.96 |
(0.40 ) |
— |
(0.40 ) |
26.84 |
17.21 |
53,272 |
0.40 |
1.50 |
2.06 |
125 |
| 12/31/24 |
26.84 |
0.65 (3) |
1.13 |
1.78 |
(0.93 ) |
— |
(0.93 ) |
27.69 |
6.60 |
49,429 |
0.65 |
1.19 |
2.25 |
77 (4) |
| 12/31/25 |
27.69 |
0.73 (3) |
11.02 |
11.75 |
(0.75 ) |
— |
(0.75 ) |
38.69 |
42.43 |
74,858 |
0.65 |
1.04 |
2.16 |
67 (4) |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
On December 1, 2023, the Predecessor Fund effected a 0.4524:1 reverse share split. All per share data has been adjusted to reflect the reverse share split. |
| (2) |
Effective December 8, 2023, Class Y shares of the Dynamic Allocation Fund were reorganized into shares of the Fund. |
| (3) |
The net investment income (loss) per share was based on average shares outstanding for the period. |
| (4) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind and received from processing subscriptions-in-kind. |
| Touchstone International Equity ETF | |||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/25(1) |
$25.00 |
$0.29 (2) |
$0.96 |
$1.25 |
$(0.16 ) |
$(0.16 ) |
$26.09 |
4.98 % (3) |
$103,050 |
0.37 % (4) |
1.01 % (4) |
1.33 %(4) |
13 % (3)(5) |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (March 3, 2025) through December 31, 2025. |
| (2) |
The net investment income (loss) per share was based on average shares outstanding for the period. |
| (3) |
Not annualized. |
| (4) |
Annualized. |
| (5) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind and received from processing subscriptions-in-kind. |
| Touchstone Large Company Growth Fund | |||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment loss |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from realized capital gains |
Total distributions |
Net asset value at end of period |
Total return(1) |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets(2) |
Ratio of gross expenses to average net assets(2) |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| Class A | |||||||||||||
| 06/30/21 |
$47.46 |
$(0.15 ) |
$16.56 |
$16.41 |
$ (6.61 ) |
$(6.61 ) |
$57.26 |
37.33 % |
$3,617 |
1.06 % |
1.59 % |
(0.71 )% |
36 % (3) |
| 06/30/22 |
57.26 |
(0.18 ) |
(10.40 ) |
(10.58 ) |
(10.52 ) |
(10.52 ) |
36.16 |
(23.29 ) |
3,290 |
1.07 |
1.58 |
(0.61 ) |
41 (3) |
| 06/30/23 |
36.16 |
(0.17 )(4) |
6.10 |
5.93 |
(1.23 ) |
(1.23 ) |
40.86 |
16.89 |
3,711 |
1.08 |
1.57 |
(0.46 ) |
44 (3) |
| 06/30/24 |
40.86 |
(0.30 )(4) |
16.72 |
16.42 |
(1.92 ) |
(1.92 ) |
55.36 |
41.47 |
5,337 |
1.07 |
1.53 |
(0.65 ) |
39 (3) |
| 06/30/25 |
55.36 |
(0.38 )(4) |
9.04 |
8.66 |
(1.61 ) |
(1.61 ) |
62.41 |
15.86 |
6,389 |
1.05 |
1.40 |
(0.68 ) |
30 (3) |
| Class C | |||||||||||||
| 06/30/21 |
$45.93 |
$(1.42 ) |
$16.81 |
$15.39 |
$ (6.61 ) |
$(6.61 ) |
$54.71 |
36.28 % |
$473 |
1.81 % |
3.39 % |
(1.46 )% |
36 % (3) |
| 06/30/22 |
54.71 |
(1.24 ) |
(9.03 ) |
(10.27 ) |
(10.52 ) |
(10.52 ) |
33.92 |
(23.87 ) |
206 |
1.82 |
4.24 |
(1.36 ) |
41 (3) |
| 06/30/23 |
33.92 |
(0.42 )(4) |
5.68 |
5.26 |
(1.23 ) |
(1.23 ) |
37.95 |
16.01 |
223 |
1.83 |
5.86 |
(1.21 ) |
44 (3) |
| 06/30/24 |
37.95 |
(0.58 )(4) |
15.41 |
14.83 |
(1.92 ) |
(1.92 ) |
50.86 |
40.43 |
216 |
1.82 |
6.43 |
(1.40 ) |
39 (3) |
| 06/30/25 |
50.86 |
(0.73 )(4) |
8.23 |
7.50 |
(1.61 ) |
(1.61 ) |
56.75 |
14.97 |
180 |
1.80 |
7.83 |
(1.43 ) |
30 (3) |
| Class Y | |||||||||||||
| 06/30/21 |
$47.97 |
$(0.26 ) |
$17.00 |
$16.74 |
$ (6.61 ) |
$(6.61 ) |
$58.10 |
37.64 % |
$28,952 |
0.81 % |
0.96 % |
(0.46 )% |
36 % (3) |
| 06/30/22 |
58.10 |
(0.18 ) |
(10.49 ) |
(10.67 ) |
(10.52 ) |
(10.52 ) |
36.91 |
(23.09 ) |
13,917 |
0.82 |
0.97 |
(0.36 ) |
41 (3) |
| 06/30/23 |
36.91 |
(0.08 )(4) |
6.24 |
6.16 |
(1.23 ) |
(1.23 ) |
41.84 |
17.17 |
7,266 |
0.83 |
1.07 |
(0.21 ) |
44 (3) |
| 06/30/24 |
41.84 |
(0.19 )(4) |
17.17 |
16.98 |
(1.92 ) |
(1.92 ) |
56.90 |
41.85 |
10,199 |
0.82 |
1.08 |
(0.40 ) |
39 (3) |
| 06/30/25 |
56.90 |
(0.25 )(4) |
9.31 |
9.06 |
(1.61 ) |
(1.61 ) |
64.35 |
16.15 |
10,726 |
0.80 |
1.01 |
(0.43 ) |
30 (3) |
| Institutional Class | |||||||||||||
| 06/30/21 |
$48.18 |
$(0.21 ) |
$17.10 |
$16.89 |
$ (6.61 ) |
$(6.61 ) |
$58.46 |
37.80 % |
$229,690 |
0.71 % |
0.85 % |
(0.36 )% |
36 % (3) |
| 06/30/22 |
58.46 |
(0.14 ) |
(10.58 ) |
(10.72 ) |
(10.52 ) |
(10.52 ) |
37.22 |
(23.03 ) |
145,441 |
0.72 |
0.84 |
(0.26 ) |
41 (3) |
| 06/30/23 |
37.22 |
(0.04 )(4) |
6.30 |
6.26 |
(1.23 ) |
(1.23 ) |
42.25 |
17.30 |
135,324 |
0.73 |
0.88 |
(0.11 ) |
44 (3) |
| 06/30/24 |
42.25 |
(0.14 )(4) |
17.35 |
17.21 |
(1.92 ) |
(1.92 ) |
57.54 |
41.99 |
137,363 |
0.72 |
0.89 |
(0.30 ) |
39 (3) |
| 06/30/25 |
57.54 |
(0.19 )(4) |
9.42 |
9.23 |
(1.61 ) |
(1.61 ) |
65.16 |
16.26 |
152,364 |
0.70 |
0.86 |
(0.33 ) |
30 (3) |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Total returns shown exclude the effect of applicable sales loads and fees. If these charges were included, the returns would be lower. |
| (2) |
The ratio of net and gross expenses to average net assets excluding liquidity provider expenses would have been lower by 0.01%, 0.03%, 0.04%, 0.03% and 0.02% for the years ended June 30, 2025, 2024, 2023, 2022 and 2021, respectively. |
| (3) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind. |
| (4) |
The net investment income (loss) per share was based on average shares outstanding for the period. |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF | |||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/25(1) |
$25.00 |
$0.10 |
$4.86 |
$4.96 |
$(0.32 ) |
$(0.32 ) |
$29.64 |
19.85 % (2) |
$8,891 |
0.79 % (3) |
2.71 % (3) |
0.46 %(3) |
26 % (2)(4) |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (February 24, 2025) through December 31, 2025. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind and received from processing subscriptions-in-kind. |
| Touchstone Sands Capital US Select Growth ETF | |||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment loss |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/25(1) |
$25.00 |
$(0.06 ) |
$3.39 |
$3.33 |
$28.33 |
13.32 % (2) |
$109,090 |
0.67 % (3) |
0.96 % (3) |
(0.33 )(3)% |
109 % (2)(4) |
| |
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (January 2, 2025) through December 31, 2025. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind and received from processing subscriptions-in-kind. |
| Touchstone Securitized Income ETF | ||||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Distributions from realized capital gains |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/23(1) |
$25.00 |
$0.73 |
$0.58 |
$1.31 |
$(0.73 ) |
$ — |
$(0.73 ) |
$25.58 |
5.37 % (2) |
$24,303 |
0.39 % (3) |
1.27 % (3) |
6.45 %(3) |
11 % (2) |
| 12/31/24 |
25.58 |
1.53 (4) |
0.31 |
1.84 |
(1.46 ) |
(0.05 ) |
(1.51 ) |
25.91 |
7.33 |
108,807 |
0.39 |
0.71 |
5.89 |
36 |
| 12/31/25 |
25.91 |
1.65 (4) |
0.24 |
1.89 |
(1.63 ) |
(0.06 ) |
(1.69 ) |
26.11 |
7.49 |
122,706 |
0.39 |
0.68 |
6.30 |
45 |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (July 17, 2023) through December 31, 2023. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
The net investment income (loss) per share was based on average shares outstanding for the period. |
| Touchstone Strategic Income ETF | ||||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Distributions from realized capital gains |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/22(1) |
$25.00 |
$0.48 |
$(0.50 ) |
$(0.02 ) |
$(0.49 ) |
$ — |
$(0.49 ) |
$24.49 |
(0.03 )% (2) |
$99,200 |
0.65 % (3) |
0.89 % (3) |
4.51 %(3) |
47 % (2) |
| 12/31/23 |
24.49 |
1.30 |
0.64 |
1.94 |
(1.27 ) |
— |
(1.27 ) |
25.16 |
8.14 |
102,522 |
0.65 |
0.87 |
5.27 |
120 |
| 12/31/24 |
25.16 |
1.25 (4) |
0.25 |
1.50 |
(1.20 ) |
(0.15 ) |
(1.35 ) |
25.31 |
6.09 |
174,668 |
0.61 |
0.87 |
4.91 |
107 |
| 12/31/25 |
25.31 |
1.35 (4) |
0.97 |
2.32 |
(1.32 ) |
(0.44 ) |
(1.76 ) |
25.87 |
9.34 |
228,929 |
0.49 |
0.81 |
5.22 |
208 |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (July 21, 2022) through December 31, 2022. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
The net investment income (loss) per share was based on average shares outstanding for the period. |
| Touchstone Ultra Short Income ETF | ||||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Distributions from realized capital gains |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/22(1) |
$25.00 |
$0.35 |
$(0.14 ) |
$0.21 |
$(0.34 ) |
$ — |
$(0.34 ) |
$24.87 |
0.87 % (2) |
$51,080 |
0.34 % (3) |
0.75 % (3) |
3.65 %(3) |
16 % (2) |
| 12/31/23 |
24.87 |
1.31 |
0.26 |
1.57 |
(1.36 ) |
— |
(1.36 ) |
25.08 |
6.47 |
60,297 |
0.31 |
0.66 |
5.28 |
87 |
| 12/31/24 |
25.08 |
1.37 (4) |
0.22 |
1.59 |
(1.34 ) |
(0.05 ) |
(1.39 ) |
25.28 |
6.50 |
99,961 |
0.25 |
0.52 |
5.41 |
85 |
| 12/31/25 |
25.28 |
1.27 (4) |
(0.01 ) |
1.26 |
(1.22 ) |
(0.01 ) |
(1.23 ) |
25.31 |
5.09 |
297,546 |
0.25 |
0.43 |
5.02 |
101 |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (August 4, 2022) through December 31, 2022. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
The net investment income (loss) per share was based on average shares outstanding for the period. |
| Touchstone US Large Cap Focused ETF | |||||||||||||
| Period ended |
Net asset value at beginning of period |
Net investment income |
Net realized and unrealized gains (losses) on investments |
Total from investment operations |
Distributions from net investment income |
Total distributions |
Net asset value at end of period |
Total return based on NAV |
Net assets at end of period (000's) |
Ratio of net expenses to average net assets |
Ratio of gross expenses to average net assets |
Ratio of net investment income (loss) to average net assets |
Portfolio turnover rate |
| 12/31/22(1) |
$25.00 |
$0.06 |
$(0.86 ) |
$(0.80 ) |
$(0.06 ) |
$(0.06 ) |
$24.14 |
(3.25 )% (2) |
$24,739 |
0.69 % (3) |
1.54 % (3) |
0.66 %(3) |
3 % (2)(4) |
| 12/31/23 |
24.14 |
0.21 |
6.09 |
6.30 |
(0.21 ) |
(0.21 ) |
30.23 |
26.17 |
31,742 |
0.69 |
1.23 |
0.79 |
3 (4) |
| 12/31/24 |
30.23 |
0.23 |
6.06 |
6.29 |
(0.23 ) |
(0.23 ) |
36.29 |
20.80 |
39,917 |
0.66 |
1.28 |
0.69 |
7 (4) |
| 12/31/25 |
36.29 |
0.23 |
5.94 |
6.17 |
(0.23 ) |
(0.23 ) |
42.23 |
17.00 |
54,897 |
0.55 |
1.17 |
0.62 |
8 (4) |
| |
|
|
|
|
|
|
|
|
|
|
|
|
|
| | |
| (1) |
Represents the period from commencement of operations (July 27, 2022) through December 31, 2022. |
| (2) |
Not annualized. |
| (3) |
Annualized. |
| (4) |
Portfolio turnover excludes securities delivered from processing redemptions-in-kind and received from processing subscriptions-in-kind. |
| |
Ticker Symbol |
Principal U.S. Listing Exchange |
| Touchstone Dividend Select ETF |
DVND |
NYSE Arca, Inc. |
| Touchstone Dynamic International ETF |
TDI |
The Nasdaq Stock Market LLC |
| Touchstone International Equity ETF |
TLCI |
NYSE Arca, Inc. |
| Touchstone Large Company Growth ETF |
TLG |
The Nasdaq Stock Market LLC |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF |
TEMX |
Cboe BZX Exchange, Inc. |
| Touchstone Sands Capital US Select Growth ETF |
TSEL |
The Nasdaq Stock Market |
| Touchstone Securitized Income ETF |
TSEC |
NYSE Arca, Inc. |
| Touchstone Strategic Income ETF |
SIO |
NYSE Arca, Inc. |
| Touchstone Ultra Short Income ETF |
TUSI |
Cboe BZX Exchange, Inc. |
| Touchstone US Large Cap Focused ETF |
LCF |
Cboe BZX Exchange, Inc. |
| |
Page |
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| 50 | |
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| 63 | |
| 64 | |
| 64 | |
| 64 | |
| 66 | |
| 67 | |
| 67 | |
| 68 | |
| 68 | |
| 69 | |
| 70 | |
| 72 | |
| 78 | |
| 79 | |
| 87 | |
| 88 | |
| 88 | |
| 89 | |
| 89 | |
| 89 | |
| 90 | |
| 95 |
| Fund |
Commencement of Operations |
| Dividend Select ETF |
August 2, 2022 |
| Dynamic International ETF |
September 30, 2004* |
| International Equity ETF |
March 3, 2025 |
| Large Company Growth ETF |
August 28, 2009** |
| Sands Capital Emerging Markets ex-China Growth ETF |
February 24, 2025 |
| Sands Capital US Select Growth ETF |
January 2, 2025 |
| Fund |
Commencement of Operations |
| Securitized Income ETF |
July 17, 2023 |
| Strategic Income ETF |
July 21, 2022 |
| Ultra Short Income ETF |
August 4, 2022 |
| US Large Cap Focused ETF |
July 27, 2022 |
| |
Dividend Select ETF |
Dynamic International ETF |
International Equity ETF(1) |
Large Company Growth ETF(2) |
Sands Capital Emerging Markets ex-China Growth ETF(3) |
Sands Capital US Select Growth ETF(4) |
Securitized lncome ETF |
Strategic Income ETF |
Ultra Short Income ETF |
US Large Cap Focused ETF |
| Gross Income from securities lending activities |
$959 |
$25,691 |
$7,306 |
$— |
$447 |
$8,539 |
$— |
$97,018 |
$— |
$— |
| Fees and/or compensation for securities lending activities and related services |
|
|
|
|
|
|
|
|
|
|
| Fees paid to securities lending agent from a revenue split |
$5 |
$781 |
$69 |
$— |
$8 |
$3,276 |
$— |
$4,221 |
$— |
$— |
| Fees paid for any cash collateral management service (including fees deducted from a pooled cash collateral reinvestment vehicle) that are not included in the revenue split |
$38 |
$999 |
$348 |
$— |
$16 |
$372 |
$— |
$3,868 |
$— |
$— |
| |
Dividend Select ETF |
Dynamic International ETF |
International Equity ETF(1) |
Large Company Growth ETF(2) |
Sands Capital Emerging Markets ex-China Growth ETF(3) |
Sands Capital US Select Growth ETF(4) |
Securitized lncome ETF |
Strategic Income ETF |
Ultra Short Income ETF |
US Large Cap Focused ETF |
| Administrative fees not included in revenue split |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
| Indemnification fee not included in revenue split |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
| Rebate (paid to borrower) |
$929 |
$20,501 |
$6,844 |
$— |
$398 |
$(13,298 ) |
$— |
$69,196 |
$— |
$— |
| Other fees not included in revenue split (specify) |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
$— |
| Aggregate fees/compensation for securities lending activities |
$972 |
$22,281 |
$7,261 |
$— |
$422 |
$(9,650 ) |
$— |
$77,285 |
$— |
$— |
| Net Income from securities lending activities |
$(13 ) |
$3,410 |
$45 |
$— |
$25 |
$18,189 |
$— |
$19,733 |
$— |
$— |
| Name Address Year of Birth |
Position Held with Trust |
Term of Office And Length of Time Served |
Principal Occupation(s) During Past 5 Years |
Number of Funds Overseen in the Touchstone Fund Complex(2) |
Other Directorships Held During the Past 5 Years(3) |
| Jill T. McGruder Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1955 |
Trustee |
Until retirement at age 75 or until she resigns or is removed Trustee since 2022 |
President of Touchstone Funds from 1999 to 2020; Director and CEO of IFS Financial Services, Inc. (a holding company) since 1999; and Senior Vice President and Chief Marketing Officer of Western & Southern Financial Group, Inc. (a financial services company) since 2016. |
40 |
Director, Integrity Life Insurance Co. and National Integrity Life Insurance Co. since 2005; Director, Touchstone Securities (the Distributor) since 1999; Director, Touchstone Advisors (the Adviser) since 1999; Director, W&S Brokerage Services, Inc. since 1999; Director, W&S Financial Group Distributors, Inc. since 1999; Director, Insurance Profillment Solutions LLC since 2014; Director, Columbus Life Insurance Co. since 2016; Director, The Lafayette Life Insurance Co. since 2016; Director, Gerber Life Insurance Company since 2019; Director, Western & Southern Agency, Inc. since 2018; and Director, LL Global, Inc. (not-for-profit trade organization with operating divisions LIMRA and LOMA) since 2016. |
| E. Blake Moore, Jr. Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1958 |
Trustee |
Until retirement at age 75 or until he resigns or is removed Trustee since 2022 |
President, Touchstone Funds from 2021 to 2025; Chief Executive Officer of Touchstone Advisors, Inc. and Touchstone Securities, Inc. from 2020 to 2025. |
40 |
Trustee, College of Wooster since 2008; |
| Name Address Year of Birth |
Position Held with Trust |
Term of Office And Length of Time Served |
Principal Occupation(s) During Past 5 Years |
Number of Funds Overseen in the Touchstone Fund Complex(2) |
Other Directorships Held During the Past 5 Years(3) |
| Karen Carnahan c/o Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1954 |
Trustee |
Until retirement at age 75 or until she resigns or is removed Trustee since 2022 |
Retired; formerly Chief Operating Officer of Shred-it (a business services company) from 2014 to 2015; formerly President & Chief Operating Officer of the document management division of Cintas Corporation (a business services company) from 2008 to 2014. |
40 |
Director, Cintas Corporation since 2019; Director, Boys & Girls Club of West Chester/Liberty from 2016 to 2022; and Board of Advisors, Best Upon Request from 2020 to 2021. |
| William C. Gale c/o Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1952 |
Trustee |
Until retirement at age 75 or until he resigns or is removed Trustee since 2022 |
Retired; formerly Senior Vice President and Chief Financial Officer of Cintas Corporation (a business services company) from 1995 to 2015. |
40 |
None. |
| Susan M. King c/o Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1963 |
Trustee |
Until retirement at age 75 or until she resigns or is removed Trustee since 2022 |
Formerly, Partner of ID Fund LLC (2020 to 2021); formerly, Senior Vice President, Head of Product and Marketing Strategy of Foresters Financial (2018 to 2020). |
40 |
Trustee, Claremont McKenna College since 2017; Trustee, Israel Cancer Research Fund since 2019. |
| Kevin A. Robie c/o Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1956 |
Trustee |
Until retirement at age 75 or until he resigns or is removed Trustee since 2022 |
Retired; formerly Vice President of Portfolio Management at Soin LLC (private multinational holding company and family office) from 2004 to 2020. |
40 |
Director, SaverSystems, Inc. since 2015; Director, Turner Property Services Group, Inc. since 2017; Trustee, Dayton Region New Market Fund, LLC (private fund) since 2010; and Trustee, Entrepreneurs Center, Inc. (business incubator) since 2006. |
| Sally J. Staley c/o Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1956 |
Trustee |
Until retirement at age 75 or until she resigns or is removed Trustee since 2023 |
Independent Consultant to Institutional Asset Owners since 2017. |
40 |
Trustee, College of Wooster from 2006 to 2025; Trustee, Great Lakes Theater Festival since 2005. |
| Name Address Year of Birth |
Position Held with Trust |
Term of Office And Length of Time Served |
Principal Occupation(s) During Past 5 Years |
Number of Funds Overseen in the Touchstone Fund Complex(2) |
Other Directorships Held During the Past 5 Years(3) |
| William H. Zimmer III c/o Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1953 |
Trustee |
Until retirement at age 75 or until he resigns or is removed Trustee since 2022 |
Independent Treasury Consultant since 2014. |
40 |
Director, Deaconess Associations, Inc. (healthcare) from 2001 to 2023. |
| Name Address Year of Birth |
Position Held with Trust(1) |
Term of Office and Length of Time Served |
Principal Occupation(s) During Past 5 Years |
| Terrie A. Wiedenheft. Touchstone Advisors, Inc. 303 Broadway, Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1962 |
President |
Until resignation, removal or disquali- fication President since July 2025 |
Senior Vice President and Chief Administration Officer within the Office of the Chief Marketing Officer of Western & Southern Financial Group (since 2021); and Senior Vice President, Chief Financial Officer, and Chief Operations Officer of IFS Financial Services, Inc. (a holding company). |
| Benjamin J. Alge Touchstone Advisors, Inc. 303 Broadway, Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1985 |
Vice President |
Until resignation, removal or disquali- fication Vice President since July 2025 |
President (since July 2025) and Divisional Vice President of Touchstone Advisors, Inc.; President (since July 2024) and Divisional Vice President of Touchstone Securities, Inc. |
| Timothy D. Paulin Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1963 |
Vice President |
Until resignation, removal or disquali- fication Vice President since 2022 |
Senior Vice President of Investment Research and Product Management of Touchstone Advisors, Inc. |
| Timothy S. Stearns Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1963 |
Chief Compliance Officer |
Until resignation, removal or disquali- fication Chief Compliance Officer since 2022 |
Chief Compliance Officer of Touchstone Advisors, Inc. and Touchstone Securities, Inc. |
| Terri A. Lucas Touchstone Advisors, Inc. 303 Broadway Suite 1100 Cincinnati, Ohio 45202 Year of Birth: 1962 |
Controller and Treasurer |
Until resignation, removal or disquali- fication Controller and Treasurer since July 2025 |
Vice President and Assistant Treasurer (since 2021); Assistant Vice President and Assistant Treasurer of Touchstone Advisors, Inc. |
| Name Address Year of Birth |
Position Held with Trust(1) |
Term of Office and Length of Time Served |
Principal Occupation(s) During Past 5 Years |
| Simon Berry Western & Southern Financial Group 400 Broadway Cincinnati, Ohio 45202 Year of Birth: 1971 |
Secretary |
Until resignation, removal or disquali- fication Secretary since 2024 |
Senior Counsel - Securities and Registered Funds of Western & Southern Financial Group (since June 2024); formerly, Senior Counsel of MassMutual Ascend Life Insurance Company |
| |
|
| ||||||||
| |
Interested Trustees |
|
Independent Trustees | |||||||
| Fund |
Jill T. McGruder |
E. Blake Moore, Jr. |
|
Karen Carnahan |
Susan M. King |
William C. Gale |
Sally J. Staley |
Kevin A. Robie |
William H. Zimmer III | |
| Dividend Select ETF |
None |
$10,001-$50,000 |
|
None |
$10,001-$50,000 |
$10,001-$50,000 |
None |
None |
$10,001-$50,000 | |
| Dynamic International ETF |
None |
$10,001-$50,000 |
|
None |
$50,001-$100,000 |
None |
$10,001-$50,000 |
Over $100,000 |
None | |
| International Equity ETF |
None |
$1-$10,000 |
|
None |
$10,001-$50,000 |
None |
None |
None |
None | |
| Large Company Growth ETF(1) |
None |
None |
|
None |
None |
None |
None |
None |
None | |
| Sands Capital Emerging Markets ex-China Growth ETF |
None |
$10,001-$50,000 |
|
None |
None |
None |
None |
None |
None | |
| Sands Capital US Select Growth ETF |
None |
$1-$10,000 |
|
None |
None |
None |
None |
None |
None | |
| Securitized Income ETF |
None |
Over$ 100,000 |
|
None |
$50,001-$100,000 |
$10,001-$50,000 |
None |
None |
None | |
| Strategic Income ETF |
None |
$1-$10,000 |
|
None |
None |
$10,001-$50,000 |
None |
None |
None | |
| Ultra Short Income ETF |
None |
Over$ 100,000 |
|
None |
$1-$10,000 |
$1-$10,000 |
None |
$50,001-$100,000 |
None | |
| US Large Cap Focused ETF |
None |
$10,001-$50,000 |
|
None |
$10,001-$50,000 |
None |
None |
None |
$10,001-$50,000 | |
| Aggregate Dollar Range of Securities in the Touchstone Fund Complex(2) |
Over $100,000 |
Over $100,000 |
|
Over $100,000 |
Over $100,000 |
Over $100,000 |
Over $100,000 |
Over $100,000 |
Over $100,000 | |
| Name |
Compensation from the Trust |
Aggregate Compensation from the Touchstone Fund Complex(1) |
| Interested Trustees |
|
|
| Jill T. McGruder |
$— |
$— |
| E. Blake Moore, Jr. |
$— |
$— |
| Independent Trustees(2) |
|
|
| Karen Carnahan |
$49,918 |
$218,000 |
| William C. Gale |
$53,215 |
$232,400 |
| Susan M. King |
$45,796 |
$200,000 |
| Kevin A. Robie |
$45,796 |
$200,000 |
| Sally J. Staley |
$45,796 |
$200,000 |
| William H. Zimmer III |
$49,918 |
$218,000 |
| |
Retainer |
Governance Committee Meeting Attendance Fees |
Audit Committee Meeting Attendance Fees |
Board Meeting Attendance Fees |
| Retainer and Meeting Attendance Fees |
$31,500 |
$6,000 |
$6,000 |
$8,000 |
| Lead Independent Trustee Fees |
$8,150 |
|
|
|
| Committee Chair Fees |
$1,500 |
$3,100 |
$3,100 |
|
| Telephonic/Virtual Meeting Attendance Fee = $2,500 |
|
|
|
|
| Limited items in-person meeting = $3,500 |
|
|
|
|
| Fund |
Investment Advisory Fee |
| Dividend Select ETF |
0.55% on the first $1 billion; and 0.50% on assets over $1 billion |
| Dynamic International ETF |
0.55% on the first $500 million; and 0.50% on assets over $500 million |
| International Equity ETF |
0.625% on the first $500 million; and 0.60% on assets over $500 million |
| Large Company Growth ETF |
0.60% on all assets |
| Sands Capital Emerging Markets ex-China Growth ETF |
0.74% on the first $200 million; 0.71% on the next $1.3 billion; and 0.69% on assets over $1.5 billion |
| Sands Capital US Select Growth ETF |
0.65% on the first $1 billion; 0.60% on the next $1 billion; 0.55% on the next $2 billion; and 0.52% on assets over $4 billion. |
| Securitized Income ETF |
0.34% on the first $500 million; and 0.30% on assets over $500 million |
| Strategic Income ETF |
0.55% on the first $250 million; 0.50% on the next $250 million; and 0.45% on assets over $500 million |
| Ultra Short Income ETF |
0.18% on the first $500 million; 0.16% on assets over $500 million |
| US Large Cap Focused ETF |
0.70% on the first $500 million; 0.65% on the next $300 million; 0.60% on the next $200 million; 0.50% on the next $1 billion; and 0.40% on assets over $2 billion |
| Fund |
Date of Fiscal Period End |
Gross Advisory Fee Paid |
Fees Waived/Recouped |
| Touchstone Dividend Select ETF |
12/31/2023 |
$154,439 |
$152,548 |
| 12/31/2024 |
$185,458 |
$175,860 | |
| 12/31/2025 |
$198,387 |
$232,982 | |
| Touchstone Dynamic International ETF(1) |
12/31/2023 |
$162,468 |
$411,731 |
| 12/31/2024 |
$298,666 |
$293,104 | |
| 12/31/2025 |
$331,359 |
$237,249 | |
| Touchstone International Equity ETF(2) |
12/31/2023 |
N/A |
N/A |
| 12/31/2024 |
N/A |
N/A | |
| 12/31/2025 |
$297,765 |
$302,575 | |
| Touchstone Large Company Growth ETF(3) |
12/31/2023 |
$944,101 |
$269,559 |
| 12/31/2024 |
$814,375 |
$259,065 | |
| 12/31/2025 |
$909,017 |
$262,792 | |
| Touchstone Sands Capital Emerging Markets Ex-China Growth ETF(4) |
12/31/2023 |
N/A |
N/A |
| 12/31/2024 |
N/A |
N/A | |
| 12/31/2025 |
$50,644 |
$131,360 | |
| Touchstone Sands Capital US Select Growth ETF(5) |
12/31/2023 |
N/A |
N/A |
| 12/31/2024 |
N/A |
N/A | |
| 12/31/2025 |
$421,371 |
$190,070 | |
| Touchstone Securitized Income ETF(6) |
12/31/2023 |
$40,658 |
$91,018 |
| 12/31/2024 |
$264,514 |
$251,272 | |
| 12/31/2025 |
$385,277 |
$325,045 | |
| Touchstone Strategic Income ETF |
12/31/2023 |
$550,096 |
$217,774 |
| 12/31/2024 |
$661,809 |
$308,710 | |
| 12/31/2025 |
$1,110,833 |
$636,641 | |
| Touchstone Ultra Short Income ETF(7) |
12/31/2023 |
$119,023 |
$184,378 |
| 12/31/2024 |
$142,971 |
$217,127 | |
| 12/31/2025 |
$329,176 |
$322,158 | |
| Touchstone US Large Cap Focused ETF |
12/31/2023 |
$199,113 |
$153,154 |
| 12/31/2024 |
$255,010 |
$225,651 | |
| 12/31/2025 |
$337,915 |
$299,524 |
| Fund |
Date of Fiscal Period End |
Sub-Advisory Fees Paid |
| Touchstone Dividend Select ETF(1) |
12/31/2023 |
$275,048 |
| 12/31/2024 |
$310,738 | |
| 12/31/2025 |
$66,459 | |
| Touchstone Dynamic International ETF(2) |
12/31/2023 |
$55,719 |
| 12/31/2024 |
$162,909 | |
| 12/31/2025 |
$180,741 | |
| Touchstone International Equity ETF(3) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$— | |
| Touchstone Large Company Growth ETF(4) |
12/31/2023 |
$503,521 |
| 12/31/2024 |
$434,905 | |
| 12/31/2025 |
$484,144 |
| Fund |
Date of Fiscal Period End |
Sub-Advisory Fees Paid |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF(5) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$18,067 | |
| Touchstone Sands Capital US Select Growth ETF(6) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$158,032 | |
| Touchstone Securitized Income ETF(7) |
12/31/2023 |
$20,329 |
| 12/31/2024 |
$132,257 | |
| 12/31/2025 |
$192,639 | |
| Touchstone Strategic Income ETF(1) |
12/31/2023 |
$77,219 |
| 12/31/2024 |
$87,209 | |
| 12/31/2025 |
$406,508 | |
| Touchstone Ultra Short Income ETF(1) |
12/31/2023 |
$38,525 |
| 12/31/2024 |
$53,613 | |
| 12/31/2025 |
$123,441 | |
| Touchstone US Large Cap Focused ETF(1) |
12/31/2023 |
$99,556 |
| 12/31/2024 |
$119,611 | |
| 12/31/2025 |
$113,201 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Daniel Strickberger |
|
|
|
|
| Registered Investment Companies |
0 |
$0 |
0 |
$0 |
| Other Pooled Investment Vehicles |
10 |
$1,154,000,000 |
0 |
$0 |
| Other Accounts |
1,419 |
$4,641,000,000 |
3 |
$923,000,000 |
| David McVey |
|
|
|
|
| Registered Investment Companies |
0 |
$0 |
0 |
$0 |
| Other Pooled Investment Vehicles |
10 |
$1,154,000,000 |
0 |
$0 |
| Other Accounts |
1,419 |
$4,641,000,000 |
3 |
$923,000,000 |
| Eric Woodworth, CFA |
|
|
|
|
| Registered Investment Companies |
0 |
$0 |
0 |
$0 |
| Other Pooled Investment Vehicles |
10 |
$1,154,000,000 |
0 |
$0 |
| Other Accounts |
1,419 |
$4,641,000,000 |
3 |
$923,000,000 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Daniel Strickberger |
None |
| David McVey |
None |
| Eric Woodworth, CFA |
None |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Austin R. Kummer, CFA |
|
|
|
|
| Registered Investment Companies |
6 |
$4,035,418,178 |
0 |
$0 |
| Other Pooled Investment Vehicles |
5 |
$1,650,556,416 |
0 |
$0 |
| Other Accounts |
141 |
$7,055,591,347 |
0 |
$0 |
| James E. Wilhelm, Jr. |
|
|
|
|
| Registered Investment Companies |
6 |
$8,723,308,623 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$54,991,666 |
0 |
$0 |
| Other Accounts |
104 |
$4,986,296,692 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Austin R. Kummer, CFA |
$50,001 - $100,000 |
| James E. Wilhelm, Jr. |
None |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Scott D. Weston |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Brent A. Miller, CFA |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Laura L. Mayfield |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Richard V. Schneider |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Scott D. Weston |
$50,001 - $100,000 |
| Brent A. Miller, CFA |
$10,001 - $50,000 |
| Laura L. Mayfield |
$10,001 - $50,000 |
| Richard V. Schneider |
None |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Daniel J. Carter, CFA |
|
|
|
|
| Registered Investment Companies |
5 |
$1,672,553,879 |
0 |
$0 |
| Other Pooled Investment Vehicles |
5 |
$2,044,239,106 |
0 |
$0 |
| Other Accounts |
122 |
$7,034,384,524 |
0 |
$0 |
| Austin R. Kummer, CFA |
|
|
|
|
| Registered Investment Companies |
6 |
$4,035,418,178 |
0 |
$0 |
| Other Pooled Investment Vehicles |
5 |
$1,455,492,516 |
0 |
$0 |
| Other Accounts |
141 |
$7,055,591,347 |
0 |
$0 |
| Brendan M. White, CFA |
|
|
|
|
| Registered Investment Companies |
1 |
$405,632,098 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$400,859,267 |
0 |
$0 |
| Other Accounts |
3 |
$403,728,716 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Daniel J. Carter, CFA |
$10,0001 - $50,000 |
| Austin R. Kummer, CFA |
$50,0001 - $100,000 |
| Brendan M. White, CFA |
$500,001 - $1,000,000 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| James E. Wilhelm, Jr. |
|
|
|
|
| Registered Investment Companies |
6 |
$8,723,308,623 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$37,860,945 |
0 |
$0 |
| Other Accounts |
104 |
$4,986,296,692 |
0 |
$0 |
| Sunit Gogia |
|
|
|
|
| Registered Investment Companies |
3 |
$5,308,216,207 |
0 |
$0 |
| Other Pooled Investment Vehicles |
0 |
$0 |
0 |
$0 |
| Other Accounts |
22 |
$1,920,060,004 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| James E. Wilhelm, Jr. |
$1 - $10,000 |
| Sunit Gogia |
$1 - $10,000 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Scott D. Weston |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Brent A. Miller, CFA |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Laura L. Mayfield |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Richard V. Schneider |
|
|
|
|
| Registered Investment Companies |
1 |
$922,254,853 |
0 |
$0 |
| Other Pooled Investment Vehicles |
1 |
$297,639,128 |
0 |
$0 |
| Other Accounts |
84 |
$4,373,271,873 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Scott D. Weston |
$50,001 - $100,000 |
| Brent A. Miller, CFA |
$10,001 - $50,000 |
| Laura L. Mayfield |
$1 - $10,000 |
| Richard V. Schneider |
$1 - $10,000 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| TJ Carter, CFA, CPA |
|
|
|
|
| Registered Investment Companies |
0 |
$0 |
0 |
$0 |
| Other Pooled Investment Vehicles |
0 |
$0 |
0 |
$0 |
| Other Accounts |
13 |
$35,500,000 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| TJ Carter |
$100,001 - $500,000 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Hal W. Reynolds, CFA |
|
|
|
|
| Registered Investment Companies |
18 |
$10,614,000,000 |
1 |
$5,781,000,000 |
| Other Pooled Investment Vehicles |
20 |
$17,153,000,000 |
6 |
$2,638,000,000 |
| Other Accounts |
36 |
$7,669,000,000 |
9 |
$4,987,000,000 |
| Ed Rackham, Ph.D. |
|
|
|
|
| Registered Investment Companies |
2 |
$229,000,000 |
0 |
$0 |
| Other Pooled Investment Vehicles |
0 |
$0 |
0 |
$0 |
| Other Accounts |
7 |
$3,000,000 |
0 |
$0 |
| Daniel Arche, CFA |
|
|
|
|
| Registered Investment Companies |
12 |
$6,729,000,000 |
0 |
$0 |
| Other Pooled Investment Vehicles |
8 |
$4,692,000,000 |
4 |
$2,094,000,000 |
| Other Accounts |
12 |
$1,145,000,000 |
1 |
$23,000,000 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Hal W. Reynolds, CFA |
$50,001 - $100,000 |
| Ed Rackham, Ph.D. |
$50,001 - $100,000 |
| Daniel Arche, CFA |
$50,001 - $100,000 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Brian A. Christiansen, CFA |
|
|
|
|
| Registered Investment Companies |
3 |
$5,081,020,000 |
0 |
$0 |
| Other Pooled Investment Vehicles |
21 |
$11,233,440,000 |
1 |
$169,950,000 |
| Other Accounts |
30 |
$7,968,610,000 |
8 |
$2,649,160,000 |
| Teeja Boye, CFA |
|
|
|
|
| Registered Investment Companies |
1 |
$2,074,250,000 |
0 |
$0 |
| Other Pooled Investment Vehicles |
12 |
$3,085,760,000 |
1 |
$169,950,000 |
| Other Accounts |
11 |
$1,645,660,000 |
4 |
$551,110,000 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Brian A. Christiansen |
$100,001 - $500,000 |
| Teeja Boye |
$50,001 - $100,000 |
| Portfolio Manager/Types of Accounts |
Total Number of Other Accounts Managed |
Total Other Assets |
Number of Other Accounts Managed subject to a Performance Based Advisory Fee |
Total Other Assets Managed subject to a Performance Based Advisory Fee |
| Wesley A. Johnston, CFA |
|
|
|
|
| Registered Investment Companies |
2 |
$2,410,970,000 |
0 |
$0 |
| Other Pooled Investment Vehicles |
7 |
$1,195,620,000 |
0 |
$0 |
| Other Accounts |
171 |
$8,669,420,000 |
4 |
$623,030,000 |
| Thomas H. Trentman, CFA |
|
|
|
|
| Registered Investment Companies |
2 |
$2,410,970,000 |
0 |
$0 |
| Other Pooled Investment Vehicles |
8 |
$1,196,800,000 |
0 |
$0 |
| Other Accounts |
178 |
$10,012,020,000 |
5 |
$730,270,000 |
| Benjamin H. Betcher, CFA |
|
|
|
|
| Registered Investment Companies |
0 |
$0 |
0 |
$0 |
| Other Pooled Investment Vehicles |
0 |
$0 |
0 |
$0 |
| Other Accounts |
0 |
$0 |
0 |
$0 |
| Portfolio Managers |
Dollar Range of Beneficial Ownership |
| Wesley A. Johnston |
$100,001 - $500,000 |
| Thomas H. Trentman |
None |
| Benjamin H. Betcher |
None |
| Fund |
Date of Fiscal Period End |
Administration Fees Paid |
| Touchstone Dividend Select ETF |
12/31/2023 |
$38,769 |
| 12/31/2024 |
$45,352 | |
| 12/31/2025 |
$48,134 | |
| Touchstone Dynamic International ETF(1) |
12/31/2023 |
$84,775 |
| 12/31/2024 |
$73,060 | |
| 12/31/2025 |
$80,352 | |
| Touchstone International Equity ETF(2) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$63,272 | |
| Touchstone Large Company Growth ETF(3) |
12/31/2023 |
$217,559 |
| 12/31/2024 |
$185,098 | |
| 12/31/2025 |
$203,229 | |
| Touchstone Sands Capital Emerging Markets Ex-China Growth ETF(4) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$9,127 | |
| Touchstone Sands Capital US Select Growth ETF(5) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$86,319 | |
| Touchstone Securitized Income ETF(6) |
12/31/2023 |
$14,267 |
| 12/31/2024 |
$104,464 | |
| 12/31/2025 |
$151,262 |
| Fund |
Date of Fiscal Period End |
Administration Fees Paid |
| Touchstone Strategic Income ETF |
12/31/2023 |
$138,112 |
| 12/31/2024 |
$161,729 | |
| 12/31/2025 |
$269,482 | |
| Touchstone Ultra Short Income ETF |
12/31/2023 |
$72,942 |
| 12/31/2024 |
$106,776 | |
| 12/31/2025 |
$243,569 | |
| Touchstone US Large Cap Focused ETF |
12/31/2023 |
$39,271 |
| 12/31/2024 |
$48,992 | |
| 12/31/2025 |
$64,395 |
| |
Aggregate Brokerage Commissions | ||
| Fund |
2023 |
2024 |
2025 |
| Touchstone Dividend Select ETF |
$1,435 |
$923 |
$1,167 |
| Touchstone Dynamic International ETF(1) |
$22,295 |
$40,332 |
$40,882 |
| Touchstone International Equity ETF(2) |
N/A |
N/A |
$10,668 |
| Touchstone Large Company Growth ETF(3) |
$32,591 |
$22,411 |
$17,960 |
| Touchstone Sands Capital Emerging Markets Ex-China Growth ETF(4) |
N/A |
N/A |
$16,374 |
| Touchstone Sands Capital US Select Growth ETF(5) |
N/A |
N/A |
$13,209 |
| Touchstone Securitized Income ETF(6) |
$0 |
$0 |
$0 |
| Touchstone Strategic Income ETF |
$10,666 |
$17,665 |
$51,576 |
| Touchstone Ultra Short Income ETF |
$0 |
$0 |
$0 |
| Touchstone US Large Cap Focused ETF |
$434 |
$369 |
$713 |
| Fund |
Amount of Transactions Directed to Brokers Providing Research |
Brokerage Commissions Related to Transactions Directed to Brokers Providing Research |
| Touchstone Dividend Select ETF |
$731,066 |
$41 |
| Touchstone Dynamic International ETF |
$74,111,574 |
$35,138 |
| Touchstone International Equity ETF(1) |
$3,300,519 |
$760 |
| Touchstone Large Company Growth ETF (Large Company Growth Fund)(2) |
$44,923,647 |
$12,691 |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF(3) |
$16,522,539 |
$13,789 |
| Touchstone Sands Capital US Select Growth ETF(4) |
$62,495,439 |
$13,208 |
| Touchstone Securitized Income ETF |
$0 |
$0 |
| Touchstone Strategic Income ETF |
$0 |
$0 |
| Touchstone Ultra Short Income ETF |
$0 |
$0 |
| Touchstone US Large Cap Focused ETF |
$187,937 |
$9 |
| Fund |
Broker/Dealer |
Aggregate Value |
| Touchstone Dividend Select ETF |
N/A |
N/A |
| Touchstone Dynamic International ETF |
N/A |
N/A |
| Touchstone International Equity ETF |
N/A |
N/A |
| Touchstone Large Company Growth ETF |
N/A |
N/A |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF |
Samsung Securities (America), Inc. |
$649,876 |
| Touchstone Sands Capital US Select Growth ETF |
N/A |
N/A |
| Touchstone Securitized Income ETF |
N/A |
N/A |
| Touchstone Strategic Income ETF |
Wells Fargo Securities, LLC |
$1,218,854 |
| Touchstone Ultra Short Income ETF |
N/A |
N/A |
| Touchstone US Large Cap Focused ETF |
N/A |
N/A |
| |
Date of Fiscal Period End |
Portfolio Turnover |
| Touchstone Dividend Select ETF |
12/31/2024(1) |
13 % |
| 12/31/2025(1) |
17 % | |
| Touchstone Dynamic International ETF |
12/31/2024(1) |
77 % |
| 12/31/2025(1) |
67 % | |
| Touchstone International Equity ETF(2) |
12/31/2024 |
N/A |
| 12/31/2025(1) |
13 % | |
| Touchstone Large Company Growth ETF (Large Company Growth Fund)(3) |
12/31/2024(1) |
39 % |
| 12/31/2025(1) |
30 % | |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF(4) |
12/31/2024 |
N/A |
| 12/31/2025(1) |
26 % | |
| Touchstone Sands Capital US Select Growth ETF(5) |
12/31/2024 |
N/A |
| 12/31/2025(1) |
109 % | |
| Touchstone Securitized Income ETF |
12/31/2024 |
36 % |
| 12/31/2025 |
45 % | |
| Touchstone Strategic Income ETF |
12/31/2024 |
107 % |
| 12/31/2025 |
208 % | |
| Touchstone Ultra Short Income ETF |
12/31/2024 |
85 % |
| 12/31/2025 |
101 % | |
| Touchstone US Large Cap Focused ETF |
12/31/2024(1) |
7 % |
| 12/31/2025(1) |
8 % |
| Fund Name and Share Class |
Name and Address |
Percentage of Class |
| Touchstone Dividend Select ETF |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
93.00 % |
| Touchstone Dynamic International ETF |
LPL Financial 1055 LPL Way Fort Mill, SC 29715 |
20.29 % |
| |
Raymond James Financial Services, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
7.28 % |
| |
Stifel, Nicolaus & Company, Incorporated 501 N Broadway St. Louis, MO 63102 |
5.70 % |
| |
Raymond James & Associates, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
5.68 % |
| Fund Name and Share Class |
Name and Address |
Percentage of Class |
| Touchstone International Equity ETF |
Cain, Watters & Associates, LLC 17 Cowboys Way Frisco, TX 75036 |
42.30 % |
| |
The London Company Of Virginia, LLC 1801 Bayberry Ct Ste 301 Richmond, VA 23226 |
37.44 % |
| |
Merrill Lynch, Pierce Fenner & Smith Inc One Bryant Park New York, NY 10036 |
9.76 % |
| |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
7.83 % |
| Touchstone Large Company Growth ETF |
Sendero Wealth Management, LLC 250 W Nottingham Dr Ste 300 San Antonio, TX 78209 |
30.97 % |
| |
Curated Wealth Partners, LLC 2321 Rosecrans Ave Ste 2215 El Segundo, CA 90245 |
20.70 % |
| |
Canterbury Consulting Incorporated 610 Newport Center Drive Newport Beach, CA 92660 |
11.14 % |
| |
Raymond James & Associates, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
8.19 % |
| |
Charles Schwab & Co Inc 101 Montgomery St San Francisco, CA 94104 |
6.78 % |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
63.40 % |
| |
Merrill Lynch, Pierce Fenner & Smith Inc One Bryant Park New York, NY 10036 |
26.95 % |
| |
J.P. Morgan Securities LLC 383 Madison Ave New York, NY 10179 |
6.58 % |
| Touchstone Sands Capital US Select Growth ETF |
A & I Financial Services 9605 S Kingston Ct Englewood, CO 80112 |
46.44 % |
| |
Echelons Capital, LLC 2078 Prospector Ave Suite 4 Park City, UT 84062 |
11.04 % |
| |
National Financial Services Corp. 200 Liberty St. New York, NY 10281 |
9.65 % |
| |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
7.76 % |
| |
Charles Schwab & Co Inc 101 Montgomery St San Francisco, CA 94104 |
6.64 % |
| Touchstone Securitized Income ETF |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
73.01 % |
| Fund Name and Share Class |
Name and Address |
Percentage of Class |
| |
Morgan Stanley Smith Barney LLC 2000 Westchester Ave Purchase, NY 10577 |
8.82 % |
| |
The Retirement Planning Group, Inc. 4811 W 136th Street Overland Park, KS 66224 |
6.76 % |
| Touchstone Strategic Income ETF |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
70.47 % |
| |
Raymond James Financial Services, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
7.00 % |
| |
Raymond James & Associates, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
5.67 % |
| |
U.S. Bank NA 1555 N. Rivercenter Drive Ste 210 Milwaukee, WI 53212 |
5.06 % |
| Touchstone Ultra Short Income ETF |
Raymond James & Associates, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
19.60 % |
| |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
14.10 % |
| |
LPL Financial 1055 LPL Way Fort Mill, SC 29715 |
13.77 % |
| |
Steward Partners Investment Advisory, LLC 140 E 45th St Fl 36 New York, NY 10017 |
6.09 % |
| |
Raymond James Financial Services, Inc. 880 Carillon Parkway Saint Petersburg, FL 33716 |
5.09 % |
| Touchstone US Large Cap Focused ETF |
Western & Southern Life Insurance Company 400 Broadway Street Cincinnati, OH 45202 |
75.26 % |
| |
Steward Partners Investment Advisory, LLC 140 E 45th St Fl 36 New York, NY 10017 |
16.18 % |
| Fund |
Standard Transaction Fee |
Maximum Variable Transaction Fee* (All Funds) |
| Dividend Select ETF |
$100 |
3 % |
| Dynamic International ETF |
$2,100 |
3 % |
| International Equity ETF |
$500 |
3 % |
| Large Company Growth ETF |
$250 |
3 % |
| Sands Capital Emerging Markets ex-China Growth ETF |
$1000 |
3 % |
| Sands Capital US Select Growth ETF |
$250 |
3 % |
| Securitized Income ETF |
$300 |
3 % |
| Strategic Income ETF |
$300 |
3 % |
| US Large Cap Focused ETF |
$100 |
3 % |
| Ultra Short Income ETF |
$300 |
3 % |
| Fund |
Standard Transaction Fee |
Maximum Variable Transaction Fee* (All Funds) |
| Dividend Select ETF |
$100 |
2 % |
| Dynamic International ETF |
$2,100 |
2 % |
| International Equity ETF |
$500 |
2 % |
| Large Company Growth ETF |
$250 |
2 % |
| Sands Capital Emerging Markets ex-China Growth ETF |
$1,000 |
2 % |
| Sands Capital US Select Growth ETF |
$250 |
2 % |
| Securitized Income ETF |
$300 |
2 % |
| Strategic Income ETF |
$300 |
2 % |
| US Large Cap Focused ETF |
$100 |
2 % |
| Ultra Short Income ETF |
$300 |
2 % |
| Fund |
Date of Fiscal Period End |
Sub-Administration Fees Paid |
| Touchstone Dividend Select ETF |
12/31/2023 |
$5,195 |
| 12/31/2024 |
$6,338 | |
| 12/31/2025 |
$6,903 | |
| Touchstone Dynamic International ETF(1) |
12/31/2023 |
$24,157 |
| 12/31/2024 |
$10,203 | |
| 12/31/2025 |
$11,535 | |
| Touchstone International Equity ETF(2) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$9,153 | |
| Touchstone Large Company Growth ETF(3) |
12/31/2023 |
$45,295 |
| 12/31/2024 |
$42,779 | |
| 12/31/2025 |
$46,514 | |
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF(4) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$1,314 | |
| Touchstone Sands Capital US Select Growth ETF(5) |
12/31/2023 |
N/A |
| 12/31/2024 |
N/A | |
| 12/31/2025 |
$12,439 | |
| Touchstone Securitized Income ETF(6) |
12/31/2023 |
$1,936 |
| 12/31/2024 |
$14,662 | |
| 12/31/2025 |
$21,683 | |
| Touchstone Strategic Income ETF |
12/31/2023 |
$18,493 |
| 12/31/2024 |
$22,624 | |
| 12/31/2025 |
$38,662 | |
| Touchstone Ultra Short Income ETF |
12/31/2023 |
$9,772 |
| 12/31/2024 |
$14,942 | |
| 12/31/2025 |
$35,060 | |
| Touchstone US Large Cap Focused ETF |
12/31/2023 |
$5,265 |
| 12/31/2024 |
$6,848 | |
| 12/31/2025 |
$9,241 |
| | |
| (a) |
|
| (b) |
|
| (c) |
Instruments defining rights of security holders with respect to the Registrant are contained in the Declaration of Trust and By-Laws, which are incorporated by reference to Exhibits (a) and (b) of Item 28 of Part C herewith. |
| (d)(1) |
|
| (d)(1)(a) |
|
| (d)(1)(b) |
|
| (d)(1)(c) |
|
| (d)(2) |
|
| (d)(3) |
|
| (d)(4) |
|
| (d)(5) |
|
| (d)(6) |
|
| (d)(7) |
|
| (d)(8) |
|
| | |
| (d)(9) |
|
| (d)(10) |
|
| (d)(11) |
|
| (e) |
|
| (e)(1) |
|
| (e)(2) |
|
| (e)(3) |
|
| (e)(4) |
|
| (e)(5) |
|
| (f) |
Not applicable. |
| (g) |
|
| (h)(1) |
|
| (h)(1)(i) |
|
| (h)(1)(ii) |
|
| (h)(2) |
|
| (h)(3) |
|
| (h)(4) |
| | |
| (h)(4)(a) |
|
| (h)(5)(a) |
|
| (h)(5)(b) |
|
| (h)(6) |
|
| (h)(6)(a) |
|
| (i) |
|
| (j) |
|
| (k) |
Not applicable. |
| (l) |
Not applicable. |
| (m) |
|
| (m)(1) |
|
| (m)(1)(a) |
|
| (n) |
Not applicable. |
| (o) |
Reserved. |
| (p)(1) |
|
| (p)(2) |
|
| (p)(3) |
|
| (p)(4) |
|
| (p)(5) |
|
| (p)(6) |
|
| (p)(7) |
|
| (q)(1) |
| Name and Position with Company |
Other Company |
Position with Other Company |
| Frank M. Sands, CFA Chief Executive Officer, Chief Investment Officer |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 Sands Capital Horizons, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Investment Board Member Executive Management Team |
| Jonathan Goodman General Counsel and Secretary |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 Sands Capital Horizons, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
General Counsel, Secretary |
| Dana McNamara Executive Managing Director, Chief Administrative Officer |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Management Team |
| Stephen Nimmo Executive Managing Director, Business Development and Client Relations |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Management Team |
| Thomas Perry Williams, CFA President, Chief Investment Officer |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Management Team |
| Brian Christiansen, CFA Executive Managing Director, Sr. Portfolio Manager, Research Analyst |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Management Team |
| Ian Ratcliffe Executive Managing Director, Executive Managing Partner |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Managing Director, Executive Managing Partner |
| Alexandra Fulk Chief Compliance Officer, Sr. Legal Counsel |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 Sands Capital Horizons, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Chief Compliance Officer, Sr. Legal Counsel |
| Name and Position with Company |
Other Company |
Position with Other Company |
| Andrew Giordano Executive Managing Director, Business Development and Client, Relations |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Management Team |
| Michael Raab, CFA Executive Managing Director, Director of Research, Portfolio, Manager, Sr. Research Analyst |
Sands Capital Alternatives, LLC 1000 Wilson Boulevard Suite 3000 Arlington, VA 22209 |
Executive Management Team |
| Name |
Address |
Position with Underwriter |
Position with Registrant |
| Teresa Cowan |
190 Middle Street, Suite 301, Portland, ME 04101 |
President/Manager |
None |
| Chris Lanza |
190 Middle Street, Suite 301, Portland, ME 04101 |
Vice President |
None |
| Kate Macchia |
190 Middle Street, Suite 301, Portland, ME 04101 |
Vice President |
None |
| Alicia Strout |
190 Middle Street, Suite 301, Portland, ME 04101 |
Vice President and Chief Compliance Officer |
None |
| Gabriel E. Edelman |
190 Middle Street, Suite 301, Portland, ME 04101 |
Secretary |
None |
| Susan L. LaFond |
190 Middle Street, Suite 301, Portland, ME 04101 |
Treasurer |
None |
| Weston Sommers |
190 Middle Street, Suite 301, Portland, ME 04101 |
Financial and Operations Principal and Chief Financial Officer |
None |
| |
| TOUCHSTONE ETF TRUST |
| By: /s/ Terrie A. Wiedenheft Terrie A. Wiedenheft President |
| Signature |
Title |
Date |
| * Karen Carnahan |
Trustee |
April 29, 2026 |
| * William C. Gale |
Trustee |
April 29, 2026 |
| * Sally J. Staley |
Trustee |
April 29, 2026 |
| * Susan M. King |
Trustee |
April 29, 2026 |
| * Kevin A. Robie |
Trustee |
April 29, 2026 |
| * William H. Zimmer III |
Trustee |
April 29, 2026 |
| * Jill T. McGruder |
Trustee |
April 29, 2026 |
| * E. Blake Moore, Jr. |
Trustee |
April 29, 2026 |
| /s/ Terri A. Lucas Terri A. Lucas |
Controller, Treasurer and Principal Financial Officer |
April 29, 2026 |
| | |
| *By: /s/ Terri A. Lucas Terri A. Lucas (Attorney-in-Fact Pursuant to Power of Attorney) |
|
Amended Schedule A
Dated April 29, 2026
to the
Expense Limitation Agreement
Dated July 1, 2022
Between
Touchstone ETF Trust and Touchstone Advisors, Inc.
FYE 12/31
| Fund | Operating Expense Limit | Termination Date | ||
| Touchstone Dividend Select ETF |
0.49% | April 29, 2027 | ||
| Touchstone Dynamic International ETF |
0.65% | April 29, 2027 | ||
| Touchstone International Equity ETF |
0.37% | April 29, 2027 | ||
| Touchstone Large Company Growth ETF |
0.67% | April 29, 2027 | ||
| Touchstone Sands Capital Emerging Markets ex-China Growth ETF |
0.79% | April 29, 2027 | ||
| Touchstone Sands Capital US Select Growth ETF |
0.67% | April 29, 2027 | ||
| Touchstone Securitized Income ETF |
0.39% | April 29, 2027 | ||
| Touchstone Strategic Income ETF |
0.49% | April 29, 2027 | ||
| Touchstone Ultra Short Income ETF |
0.25% | April 29, 2027 | ||
| Touchstone US Large Cap Focused ETF |
0.55% | April 29, 2027 |
This Schedule A to the Expense Limitation Agreement is hereby executed as of the date first set forth above.
| TOUCHSTONE ETF TRUST | ||
| By: | /s/ Terri A. Lucas | |
| Name: Terri A. Lucas | ||
| Title: Controller and Treasurer | ||
| TOUCHSTONE ADVISORS, INC. | ||
| By: | /s/ Benjamin J. Alge | |
| Name: Benjamin J. Alge | ||
| Title: President | ||
| By: | /s/ Terrie A. Wiedenheft | |
| Name: Terrie A. Wiedenheft | ||
| Title: Chief Financial Officer | ||
April 29, 2026
Touchstone ETF Trust
303 Broadway, Suite 1100
Cincinnati, Ohio 45202
Ladies and Gentlemen:
We have acted as counsel to Touchstone ETF Trust, a Delaware statutory trust (the “Trust”), in connection with Post-Effective Amendment No. 14 (the “Post-Effective Amendment”) to the Trust’s registration statement on Form N-1A (File Nos. 333-264194; 811-23789) (the “Registration Statement”), to be filed with the U. S. Securities and Exchange Commission (the “Commission”) on or about April 29, 2026, registering an indefinite number of shares of beneficial interest in the series of the Trust (the “Shares”), under the Securities Act of 1933, as amended (the “Securities Act”).
This opinion letter is being delivered in accordance with the requirements of paragraph 29 of Schedule A of the Securities Act and Item 28(i) of Form N-1A under the Securities Act and the Investment Company Act of 1940, as amended (the “Investment Company Act”).
For purposes of this opinion letter, we have examined originals, or copies, certified or otherwise identified to our satisfaction, of such certificates, records and other documents as we have deemed necessary or appropriate for the purpose of this opinion.
We also have examined and relied on certificates of public officials and, as to certain matters of fact that are material to our opinions, we have relied on a certificate of an officer of the Trust. We have not independently established any of the facts on which we have so relied.
For purposes of this opinion letter, we have assumed the accuracy and completeness of each document submitted to us, the genuineness of all signatures on original documents, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as facsimile, electronic, certified, conformed, or photostatic copies thereof, and the due execution and delivery of all documents where due execution and delivery are prerequisites to the effectiveness thereof. We have further assumed the legal capacity of natural persons, that persons identified to us as officers of the Trust are actually
Touchstone ETF Trust
April 29, 2026
Page 2
serving in such capacity, and that the representations of officers of the Trust are correct as to matters of fact. We have not independently verified any of these assumptions.
The opinions expressed in this opinion letter are based on the facts in existence and the laws in effect on the date hereof and are limited to the Delaware Statutory Trust Act and the provisions of the Investment Company Act that are applicable to equity securities issued by registered open-end investment companies. We are not opining on, and we assume no responsibility for, the applicability to or effect on any of the matters covered herein of any other laws.
Based upon and subject to the foregoing, it is our opinion that (1) the Shares to issued pursuant to the Post-Effective Amendment, when issued and paid for by the purchasers upon the terms described in the Registration Statement, will be validly issued, and (2) such purchasers will have no obligation to make any further payments for the purchase of the Shares or contributions to the Trust solely by reason of their ownership of the Shares.
This opinion is rendered solely in connection with the filing of the Post-Effective Amendment and supersedes any previous opinions of this firm in connection with the issuance of Shares. We hereby consent to the filing of this opinion with the Commission in connection with the Post-Effective Amendment. In giving this consent, we do not thereby admit that we are experts with respect to any part of the Registration Statement within the meaning of the term “expert” as used in Section 11 of the Securities Act or the rules and regulations promulgated thereunder by the Commission, nor do we admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act or the rules and regulations of the Commission promulgated thereunder.
| Very truly yours, |
| /s/ K&L Gates LLP |
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
We consent to the references to our firm under the captions “Financial Highlights” in the Prospectus and the reference to our firm in the Statement of Additional Information, including references under the captions “Independent Registered Public Accounting Firm” and “Financial Statements”, each dated April 30, 2026, and each included in this Post-Effective Amendment No. 14 to the Registration Statement (Form N-1A, File No. 333-264194) of Touchstone ETF Trust (the “Registration Statement”).
We also consent to the incorporation by reference of our report dated February 13, 2026, with respect to the financial statements and financial highlights of Touchstone Dividend Select ETF, Touchstone Dynamic International ETF, Touchstone International Equity ETF, Touchstone Sands Capital Emerging Markets ex-China Growth ETF, Touchstone Sands Capital US Select Growth ETF, Touchstone Securitized Income ETF, Touchstone Strategic Income ETF, Touchstone Ultra Short Income ETF, and Touchstone US Large Cap Focused ETF (the “Funds”) (nine of the funds constituting Touchstone ETF Trust) included in the Annual Report to Shareholders (Form N-CSR) for the year ended December 31, 2025, into this Registration Statement filed, with the Securities and Exchange Commission.
We also consent to the incorporation by reference of our report dated August 15, 2025, with respect to the financial statements and financial highlights of Touchstone Large Company Growth ETF (one of the funds constituting Touchstone ETF Trust) included in the Annual Report to Shareholders (Form N-CSR) for the year ended June 30, 2025, into this Registration Statement filed, with the Securities and Exchange Commission.
Cincinnati, Ohio
April 29, 2026
CODE OF ETHICS
Most Recent Amendment: October 2025
Implementation Date: 2004
|
|
PURPOSE
Sands Capital Management, LLC (“Sands Capital Management”) and its investment advisory affiliates (“Sands Capital”) have adopted this Code of Ethics and its related policies (this “Code”) pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and Rule 17j-1 of the Investment Company Act of 1940, as amended (the “‘40 Act”).
The Advisers Act requires an investment adviser to adopt, maintain and enforce a written code of ethics regarding:
| 1. | The investment adviser’s fiduciary duties to clients; |
| 2. | Compliance with applicable federal securities laws; |
| 3. | The reporting and review of personal securities transactions and holdings; |
| 4. | The pre-approval of certain investments; |
| 5. | The reporting of violations of the code of ethics; and |
| 6. | The delivery of the code of ethics and any amendments thereto to each supervised person of the investment adviser and a written acknowledgment of receipt. |
The ‘40 Act requires the investment adviser to an investment company to adopt, maintain and enforce a written code of ethics reasonably necessary to prevent relevant persons from engaging in fraudulent, deceptive, or manipulative practices in connection with their personal transactions in securities when those securities are held or to be acquired by the investment company.
SCOPE
This Code applies to each Access Person (as defined below). The Chief Compliance Officer (“CCO”) has the discretion to exempt any Supervised Person (as defined below) from provisions of this Code, provided doing so would not violate applicable law or regulation.
DEFINITIONS
“Access Person” means Sands Capital’s directors, officers, partners, and Supervised Persons who (1) have access to nonpublic information regarding any client’s purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any reportable fund, or (2) are involved in making securities recommendations to clients, or who have access to such recommendations that are nonpublic. Sands Capital generally considers all Staff Members to be Access Persons.
“Beneficial Owner” means any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise has or shares a direct or indirect pecuniary interest in a security.
| 1
|
“Federal Securities Laws” includes the Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm-Leach-Bliley Act, and any rules adopted by the U.S. Securities and Exchange Commission (the “SEC”) under any of those statutes, the Bank Secrecy Act as it applies to registered investment advisers and investment companies, and any rules adopted thereunder by the SEC or the Department of the Treasury.
“Free Trading Securities” means securities that are freely tradable without seeking preclearance and without regard to an open trading window. These include:
| ● | Exchange-traded funds (“ETFs”), except for highly concentrated ETFs*; |
| ● | Mutual funds*; |
| ● | Exchange-traded notes (“ETNs”)*; |
| ● | Annuities; |
| ● | REITs; |
| ● | Systematic investment plans; |
| ● | Foreign currency contracts; |
| ● | Cryptocurrency on Coinbase’s listed assets (https://www.coinbase.com/browse); and; |
| ● | Any securities that are not Reportable Securities. |
* ETFs and mutual funds advised or sub-advised by Sands Capital are Free Trading Securities. However, Staff Members should contact the Compliance team to obtain pre-clearance before trading in any ETF or ETN that holds few positions or is otherwise highly concentrated.
“Immediate Family Member” means the following persons sharing an Access Person’s household: child, stepchild, grandchild, parent, stepparent, grandparent, spouse, domestic partner, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, and shall include adoptive relationships.
“Outside Business Activity” means any employment or other outside activity by a Supervised Person.
“Reportable Security” means any security, except:
| 1. | Transactions and holdings in direct obligations of the U.S. government (e.g., U.S. Treasury bills, notes and bonds). |
| 2. | Money market instruments — bankers’ acceptances, U.S. bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments. |
| 3. | Shares of money market funds. |
| 4. | Transactions and holdings in shares of other types of open-end investment companies (i.e., mutual funds), unless the adviser or a control affiliate acts as the investment adviser or principal underwriter for the fund. |
| 5. | Transactions in units of a unit investment trust that are invested exclusively in unaffiliated mutual funds. |
“Staff Member” means Sands Capital’s directors, officers, partners, and employees. Any consultant, intern, or independent contractor hired or engaged by Sands Capital may also be considered a Staff Member for purposes of this Code at the discretion of the CCO.
2
“Supervised Person” means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of Sands Capital, other person who provides investment advice on behalf of Sands Capital and is subject to the supervision and control of Sands Capital, or any individual the CCO deems a Supervised Person. Sands Capital considers all Staff Members to be Supervised Persons.
CODE OF CONDUCT, FIDUCIARY STANDARDS, AND COMPLIANCE WITH FEDERAL SECURITIES LAWS
Each Staff Member is considered a Supervised Person and generally considered an Access Person of Sands Capital Management. Staff Members whose responsibility involves performing services with respect to an investment advisory affiliate are also Supervised Persons of Sands Capital Management. Staff Members must act ethically with integrity, competence, and dignity when dealing with the public, existing and prospective clients, third-party service providers, and colleagues. Staff Members must not engage in risky activity or improper behavior that would embarrass or harm Sands Capital’s reputation. Staff Members must use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, trading, promoting Sands Capital’s services, and engaging in other professional activities. In addition, Staff Members must comply with all applicable Federal Securities Laws and adhere to these general principals and the specific provisions of this Code at all times. All Staff Members shall certify in writing upon hire and at least annually that they have received, read and understand this Code, which should be read together with the Sands Capital Policies and Procedures Manual (the “Manual”) and will comply with the requirements of this Code and the Manual.
Sands Capital owes fiduciary obligations to its clients. As a fiduciary, Sands Capital stands in a special relationship of trust, confidence, and responsibility to its clients. Accordingly, Sands Capital and its Staff Members must avoid activities, interests, and relationships that might interfere, or appear to interfere, with making decisions in clients’ best interests. Staff Members must always seek to place clients’ interests before their interests or the interests of Sands Capital. Staff Members may not cause a client to take any action, or not to take any action, for the personal benefit of the Staff Member, and must act for the sole benefit of Sands Capital’s clients and investors.
VIOLATIONS OF THE CODE
Improper actions by Sands Capital or its Staff Members could have severe negative consequences for Sands Capital and its clients, investors, and Staff Members. Impropriety, or even the appearance of impropriety, could negatively impact all Staff Members, including those who were not involved in the inappropriate activity.
Staff Members must promptly report any improper or suspicious activities to the CCO, including any suspected violations of this Code or applicable laws. Issues can be reported to the CCO in person, by telephone, email, or anonymously through Navex Global, which is available through the Sands Capital intranet. The CCO will investigate any reports of potential problems.
Sands Capital’s senior executives will view a Staff Member’s identification of a material compliance issue favorably. Retaliation against any Staff Member who reports a violation of this Code in good faith is strictly prohibited and will be cause for corrective action, up to and including dismissal. If Staff Members believe
3
they have been retaliated against, they should notify the Head of Human Resources or Sands Capital’s other senior management.
Violations of this Code, or other policies and procedures outlined in the Manual, which should be read together with this Code, may warrant sanctions including, without limitation, requiring that personal trades be reversed, requiring the disgorgement of profits or gifts, issuing a letter of caution or warning, reporting to the Staff Member’s supervisor, suspending personal trading rights, imposing a fine, taking misconduct into account when making compensation decisions, suspending employment (with or without compensation), making a civil referral to the SEC, making a criminal referral, terminating employment for cause, and a combination of the preceding. Violations may also subject a Staff Member to civil, regulatory, or criminal sanctions. Sanctions and other actions will be in accordance with applicable employment laws and regulations. All violations of the Code will be recorded on the violations log.
If the CCO determines that a material violation of the Code has occurred, the CCO will promptly report the offense and any association action(s) to Sands Capital’s senior management. If senior management determines that the material violation may involve a fraudulent, deceptive, or manipulative act, Sands Capital will report its findings to the relevant registered investment company’s Board of Directors or Trustees to the extent required under Rule 17j-1.
For the avoidance of doubt, nothing in this Code prohibits Staff Members from reporting potential violations of federal law or regulation to any governmental agency or entity, including but not limited to the Department of Justice, the SEC, or any agency’s inspector general, or from making other disclosures that are protected under the whistleblower provisions of federal law or regulation. Staff Members do not need prior authorization from their supervisor, the CCO, or any other person or entity affiliated with Sands Capital to make any such reports or disclosures and do not need to notify Sands Capital that they have made such reports or disclosures. Additionally, nothing in this Code prohibits Staff Members from recovering an award under a whistleblower program of a government agency or entity.
In certain circumstances, violations of the Code or Federal Securities Laws may warrant Sands Capital to disclose the misconduct to regulators or other governmental authorities. In such an instance, the CCO and General Counsel will determine whether self-disclosure is in the best interest of Sands Capital’s clients and investors. Sands Capital is committed to fostering a strong culture of compliance at all levels of the firm.
INELIGIBLE PERSONS
Under Section 9 of the ‘40 Act, persons who have committed various acts are prohibited from serving in certain capacities with respect to mutual funds. Under Section 9(a), an “ineligible person” generally cannot serve as an employee, officer, trustee, member of the advisory board, investment adviser, or principal underwriter of a fund. Ineligible persons include:
| ● | persons with convictions within the last ten years who are tied to securities transactions or employment in the securities field; |
| ● | persons with permanent or temporary injunctions from acting in certain capacities in the securities arena; |
| ● | persons who have an affiliate that is ineligible under clause (1) or (2) above; or |
| ● | persons subject to an SEC order declaring them ineligible under Section 9 of the ‘40 Act. |
4
A Staff Member who becomes an “ineligible person” (or who believes they may have hired or employed an “ineligible person”) as described above must promptly notify Compliance.
CONFLICTS OF INTEREST
Conflicts of interest may exist between various individuals and entities, including Sands Capital, Staff Members, third-party service providers, and current or prospective clients and investors. Failure to identify or adequately address a conflict can have severe negative repercussions for Sands Capital and its Staff Members, clients, and investors. In some cases, the improper handling of a conflict could result in litigation and disciplinary action.
Sands Capital’s policies and procedures have been designed to identify and adequately disclose, mitigate, and/or eliminate applicable conflicts of interest. However, written policies and procedures cannot address every potential conflict, so Staff Members must use good judgment in identifying and responding appropriately to actual or apparent conflicts. Conflicts of interest that involve Sands Capital or Staff Members on the one hand, and clients or investors on the other, will generally be fully disclosed or resolved in a way that favors the interests of clients or investors over the interests of Sands Capital and its Staff Members. Staff Members must promptly report any actual or potential conflict of interest to Compliance.
In some instances, conflicts of interest may arise between clients or investors. Responding appropriately to these types of conflicts can be challenging and may require robust disclosures if there is any appearance that one or more clients or investors have been unfairly disadvantaged. Staff Members should notify a member of the Compliance team promptly if it appears that any actual or apparent conflict of interest between clients or investors has not been appropriately identified or addressed.
Sands Capital Conflicts Board. The Conflicts Board is responsible for providing oversight over actual, potential, or apparent material conflicts of interest on behalf of Sands Capital. The Conflicts Board reviews and resolves situations involving enterprise or investment risks escalated to it by Compliance or Legal.
PERSONAL SECURITIES TRANSACTIONS
Personal trades should be executed in a manner consistent with Sands Capital’s fiduciary obligations to clients. Trades should avoid actual improprieties, as well as the appearance of impropriety. Personal trades must not be timed to precede orders placed for any client, nor should the trading activity be so excessive as to conflict with the Staff Member’s ability to fulfill daily job responsibilities.
In the event of a material change to this section of this Code, the CCO shall notify each applicable registered investment company’s board of directors or trustees of such modification and ensure that the change is approved by each no later than six months after the change is adopted.
Reportable Accounts. Sands Capital’s policies and procedures apply to all personal accounts holding securities in which Staff Members or their Immediate Family Members have any beneficial ownership interest.
Non-discretionary accounts, also known as managed accounts, must be reported and require an attestation
5
from the Staff Member and account manager stating that the Staff Member does not exercise direct or indirect influence or control the investment decisions for the account. Staff Members should contact Compliance to obtain the appropriate forms. Staff Members are required to confirm the attestations and must report managed account holdings upon hire and on an annual basis.
Reportable Securities. Sands Capital requires Staff Members to provide periodic reports regarding transactions and holdings in Reportable Securities, including investments in private investments, IPOs and/or ICOs (See Required Reporting, below). ETFs, and ETNs, are, or are somewhat similar to, open-end registered investment companies. However, both ETFs and ETNs are subject to the reporting requirements described in Required Reporting below.
Pre-Clearance Requirements. Staff Members and Immediate Family Members are required to pre-clear all personal securities transactions (for example, individual stocks and corporate bonds) except for personal securities transactions in Free Trading Securities, those pursuant to an automatic investment plan (including dividend reinvestment plans), and those made within a non-discretionary account. Staff Members must submit pre-clearance requests through Sands Capital’s compliance management system and obtain written Compliance approval prior to engaging in relevant personal securities transactions.
Compliance has the discretion to approve or decline any pre-clearance request. Any Compliance pre- approval, if granted, is valid until the end of the day when the pre-clearance request is approved plus the following trading day, unless determined otherwise by the CCO. Pre-clearance requests may be denied for various reasons, including but not limited to, the existence of conflicts of interest or the appearance of conflicts of interest, the security being listed on the Sands Capital restricted list (a confidential list of securities for which personal trading is not permitted), and/or Sands Capital’s possession of material, nonpublic information.
Open Windows. Sands Capital allows personal securities transactions during “Open Windows,” which generally occur monthly, and permits Staff Members to buy and sell equities for the duration of the Open Window. Sands Capital may, in its discretion, establish Open Windows for specific securities between monthly Open Windows.
Compliance will communicate the dates of Open Windows to all Staff Members in advance.
Private Investments, IPOs, and ICOs. All investments and redemptions involving private or limited offerings, initial public offerings (“IPOs”), and initial coin offerings (“ICOs”) require Staff Members to submit a pre-clearance request through Sands Capital’s compliance management system. Pre-clearance requests should include relevant documentation, such as pitch decks, PPMs, LPAs, etc. Reviews of these requests require additional Compliance scrutiny and may take several days to complete. Compliance advises Staff Members to submit the pre-clearance request as early as possible so as not to delay the review.
Investments into Sands Capital’s private funds do not require Staff Members to submit a preclearance request through Sands Capital’s compliance management system, however, Staff Members will be required to submit subscription agreements to Sands Capital before an investment in such private fund can occur. Sales of distributions of stock from a Sands Capital private fund are subject to the same trading restrictions
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and reporting requirements as other individual equity securities, however, the 90-day holding requirement does not apply. Information on investing in any such private fund will be communicated to eligible Staff Members.
Investments by Staff Members in Sands Capital Management, LP do not require pre-approval or reporting through Sands Capital’s compliance management system.
Trading. Staff Members seeking approval to transact during an Open Window are subject to the following conditions:
| ● | Sales: Compliance will consider pre-clearance requests to sell any Reportable Security held by the Staff Member. |
| ● | Purchases: Compliance will only consider pre-clearance requests to purchase individual equity securities that are included in the portfolio of a Sands Capital strategy. |
Holding Periods. Individual equity securities must be held for a minimum of 90 calendar days. All other securities must be held for a minimum of 30 calendar days unless the sale of the security would result in a loss.
Options, Other Derivatives, and Short Sales. Staff Members are strictly prohibited from engaging in personal trading activities involving options, derivatives, and short selling.
Exceptions. The CCO has the sole discretion to grant exceptions to this Personal Securities Transaction policy, for example, due to an unforeseen hardship (e.g., the purchase of a home or a significant medical expense). From time to time, an exception may be granted on a case-by-case basis after the consideration of all relevant facts and circumstances, if appropriate.
REQUIRED REPORTING
Initial and Annual Holdings Report(s). All Staff Members are required to disclose their Reportable Accounts, and holdings in Reportable Securities, including private investments, at the time of hire and at least once a year thereafter. The Initial Holdings Report must be submitted within 10 days of the individual becoming a Staff Member and on an annual basis thereafter (the Annual Holdings Report). The holdings report information contained in a Staff Member’s Initial Holdings Report and Annual Holdings Report must be current as of a date no more than 45 days prior to the date of submission through Sands Capital’s compliance management system.
Quarterly Transactions Report. Staff Members are required to submit a Quarterly Transactions Report of all personal transactions in Reportable Securities, including any investments in private investments, IPOs and/or ICOs, which is due no later than 30 days after the relevant calendar quarter-end. For purposes of clarity, personal securities transactions that are executed pursuant to an automatic investment plan or through a managed account do not need to be disclosed on the Quarterly Transactions Report (although any such holdings must be included on a Staff Member’s Initial Holdings Report and Annual Holdings Report).
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Staff Members should connect their Reportable Accounts that hold Reportable Securities to Sands Capital’s compliance management system to satisfy their reporting requirements. In the event this is not possible, Staff Members should notify the CCO or a Compliance team member. If approved by the CCO, monthly or quarterly account statements can be used to satisfy the disclosure requirements as an alternative to the compliance management system, provided the account statement(s) includes all transactions in Reportable Securities effected during the period and includes, at a minimum, all the following:
| ● | the date of each transaction, the title, and as applicable, the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each security involved; |
| ● | the nature of the transaction (i.e., purchase, sale, or any other type of acquisition or disposition); |
| ● | the price of the security at which the transaction was effected; |
| ● | the name of the firm with or through which the transaction was effected; and |
| ● | the date the Staff Member submits the report. |
Staff Members will receive an automated notification and periodic reminders that they must complete the Quarterly Transaction Report in Sands Capital’s compliance management system. The Compliance team will review Quarterly Transaction Reports to ensure that Staff Members have followed the policies.
Additional Reporting. Staff members are also required to report and certify to any outside business activities, political contributions, and disciplinary history upon hire and annually thereafter. Compliance may also require Staff Members to seek approval for outside business activities and political contributions, as further described in this Code.
GIFTS AND ENTERTAINMENT
Sands Capital holds its Staff Members to high ethical standards and prohibits giving or receiving things of value that are designed to improperly influence the recipient. Anti-bribery and anti-corruption statutes in the U.S. and globally are broadly written, so Staff Members should consult with the CCO if there is even an appearance of impropriety associated with the giving or receipt of anything of value.
Under the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), plan sponsors and fiduciaries of covered pension plans must exercise caution in accepting any gifts or gratuities from a service provider (including investment advisers), even those of reasonable value. Specifically, Section 406(b)(3) of ERISA makes it unlawful for a plan fiduciary to receive any consideration for its own personal account from any party dealing with the plan in connection with a transaction involving the assets of the plan.
While these requirements apply primarily to plan fiduciaries as the potential recipients of gifts or entertainment (rather than the giver), to prevent Sands Capital as a service provider from running afoul of ERISA and non-ERISA rules in these areas, Sands Capital requires that, with respect to ERISA and non- ERISA public pension plan clients, no gifts be given (other than immaterial token gifts, e.g., investor conference gift handouts) and no extravagant entertainment be provided without consulting with the CCO so they may be reviewed in advance for reasonableness and appropriateness. Certain clients or prospects
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maintain internal policies that prohibit Sands Capital and its Staff members from giving anything of value to their employees and/or representatives. In such cases, relevant Staff members will be notified by the Compliance team of such restrictions.
The Foreign Corrupt Practices Act of 1977 (“FCPA”) prohibits the direct or indirect giving of, or a promise to give, “things of value” in order to corruptly obtain a business benefit from an officer, employee, or other “instrumentality” of a foreign government. Companies owned, even partly, by a foreign government may be considered an “instrumentality” of that government. In particular, government investments in foreign financial institutions may apply the FCPA to those institutions. Individuals acting in an official capacity on behalf of a foreign government or a foreign political party may also be “instrumentalities” of a foreign government.
The FCPA includes provisions that may permit giving gifts and entertainment under certain circumstances, including certain gifts and entertainment that are lawful under the written laws and regulations of the recipient’s country, as well as bona fide travel costs for certain legitimate business purposes. However, the availability of these exceptions is limited and is dependent on the relevant facts and circumstances. Civil and criminal penalties for violating the FCPA can be severe. See Sands Capital’s Foreign Corrupt Practices Act Policy for additional information.
Staff Members are prohibited from giving or receiving gifts or entertainment that may appear lavish or excessive and must obtain Compliance approval to give or receive gifts of more than $250 USD per year or entertainment of more than $500 USD per year (the “de minimis amount”) per individual that Sands Capital does or seeks to do business with. These limitations are in addition to the FCPA-related restrictions and the restrictions regarding pension plans described herein. Gifts such as holiday baskets or lunches delivered to Sands Capital offices, which are received on behalf of Sands Capital, do not require reporting.
Staff Members must pre-clear and obtain Compliance approval for any gifts and/or entertainment requests above the relevant de minimis amounts through Sands Capital’s compliance management system.
OUTSIDE BUSINESS ACTIVITIES
Business activities outside of work may present a conflict of interest or risk that could harm Sands Capital, its clients, or its investors. For instance, work that is investment-related or involves a significant amount of time or provides substantial income may conflict with a Staff Member’s work at Sands Capital. For Sands Capital to identify and manage conflicts and risks, Staff Members must disclose and request Compliance pre-approval through Sands Capital’s compliance management system prior to participating in any outside business activity. Staff Members may not share confidential information obtained through their outside business activities with other Staff Members. Any outside business activity that involves service on the board of directors of a publicly traded company will generally not be permitted. At all times, the interests of Sands Capital’s clients take priority over the outside business activities of Staff Members.
Exceptions. Staff Members are not required to disclose or seek pre-clearance for unpaid service as a volunteer for a non-profit entity, including civic organizations (e.g., a local homeowners or resident association) unless the Staff Member performs investment-related functions on its behalf. Staff Members
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may also serve on a Sands Capital portfolio company’s board of directors without separate disclosure or pre-clearance under this Code; however, such participation on a board may be subject to other policies of Sands Capital.
POLITICAL AND CHARITABLE CONTRIBUTIONS
Rule 206(4)-5 under the Advisers Act (the “Pay-to-Play Rule”) was adopted by the SEC to combat “pay- to-play” arrangements in which investment advisers are chosen based on their campaign contributions to political officials rather than on merit. Such arrangements are viewed by the SEC as a breach of an investment adviser’s fiduciary duties.
The Pay-to-Play Rule prohibits an investment adviser from:
| 1. | receiving compensation from a government entity for advisory services for two years following contributions by the investment adviser (or non de minimis contributions by a covered associate) (as defined below) to any official of that government entity; |
| 2. | paying (or agreeing to pay) any person, directly or indirectly, to solicit a government entity for investment advisory services unless such person is a regulated person (such as certain investment advisers or brokers) or an employee of the investment adviser; or |
| 3. | coordinating, or soliciting any person or political action committee to make, (a) any contribution to an official of a government entity to which the adviser is providing or seeking to provide investment advisory services; or (b) payment to a political party of a State or locality where the adviser is providing or seeking to provide investment advisory services to a government entity. |
A “covered associate” of an investment adviser means any: (1) general partner, managing member or executive officer, or other individuals with a similar status or function, of the adviser; (2) any employee of the adviser that solicits a government entity for the adviser, as well as any direct or indirect supervisor of that employee; and (3) political action committee controlled by the adviser or any person that meets the definition of a “covered associate”.
“Contributions” means any gifts, loans, payment of debts, or provision of any other thing of value made for purposes of influencing a federal, state, or local election, including payments of campaign debts and transition or inaugural expense incurred by successful candidates for state or local (but not federal) office. The definition may also include contributions to political parties or political action committees if such contributions are attributed to a particular candidate. The definition does not include the provision of personal time (such as volunteering time to a political campaign outside of working hours).
To ensure compliance with the Pay-to-Play Rule, Sands Capital has adopted in this Code certain policies and procedures with respect to political and charitable contributions and solicitation arrangements.
Political Contributions. Staff Members and their Immediate Family Members are prohibited from soliciting from others, or coordinating, contributions to certain elected officials or candidates or payments to political parties where the adviser is providing or seeking government business. Further, Staff Members and their Immediate Family Members are prohibited from making any other political contributions unless they receive CCO approval.
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If a Staff Member or their Immediate Family Member intends to make any political contribution (whether to a state or local government entity, an official, a candidate, a political party, or political action committee) the Staff Member must seek pre-clearance using Sands Capital’s compliance management system. If pre-clearance is granted, it is valid for seven days before and after the intended contribution date. Any contributions outside of this date range require re-approval. The CCO will consider whether the proposed contribution is consistent with restrictions imposed by the Pay-to-Play Rule, and to the extent practicable, the CCO will seek to protect the confidentiality of all information regarding each proposed contribution. Generally, pre-clearance requests will be approved if:
| 1. | The Staff Member is entitled to vote at the time of the contribution and contributions in the aggregate do not exceed $350 to any one official, per election; or |
| 2. | The Staff Member is not entitled to vote at the time of the contribution and contributions in the aggregate do not exceed $150 to any one official, per election. |
| 3. | The contribution is requested to be made to a national political candidate or party and the recipient does not otherwise hold a state or local political office. |
Sands Capital generally requires that a Staff Member donating to a political action committee or similar group obtain a certification from such committee or group that contributions will not be used to make or provide, directly or indirectly, (i) any gift, subscription, loan, advance or deposit of money or anything of value, to any official of, or candidate for, a U.S. state or local office or political subdivision, including any agency, authority or instrumentality of such U.S. state or political subdivision or any official of a U.S. state or local office or political subdivision seeking a federal elective office, or (ii) payment to a political party of a U.S. state or locality, including any election committee.
Any political contribution by Sands Capital must receive CCO approval, regardless of the proposed amount or recipient of the contribution. The CCO or his or her designee will maintain a chronological list of contributions in accordance with the requirements of the Pay-to-Play Rule and Rule 204-2(a)(18) under the Advisers Act, as well as a list of all clients and investors that meet the definition of a “government entity” for purposes of Rule 206(4)-5.
The restrictions imposed by the Pay-to-Play Rule can apply to the activities of Staff Members involved in soliciting clients or investors for the two years before they became covered associates of Sands Capital and the six months before they became covered associates for those not involved in soliciting clients or investors.
Solicitation Arrangements. Sands Capital will only compensate third parties for referrals of clients or investors that are affiliated with government entities if the solicitor is an eligible “regulated person,” as defined by Rule 206(4)-5 and if the solicitor and its covered associates have not made any disqualifying contributions during the past two years.
The CCO is responsible for reviewing the eligibility of all solicitation arrangements that involve, or are expected to involve, government entities.
Charitable Donations. Donations by Sands Capital or Staff Members to charities with the intention of
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influencing such charities to become clients or investors are prohibited. Staff Members should notify the CCO about any actual or apparent conflict of interest in connection with any charitable contribution or any contribution that could give an appearance of impropriety.
BOOKS AND RECORDS
Sands Capital will maintain records relating to this Code in the manner and as required by Rule 204-2(a)(12) and (13) under the Advisers Act and Rules 17j-1(f) and 31a-1(f) under the ‘40 Act.
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