Form 40-17F2 USAA ETF Trust Filed by: USAA ETF Trust

September 7, 2018 12:16 PM EDT

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

FORM N-17f-2

Certificate of Accounting of Securities and Similar

Investments in the Custody of

Management Investment Companies

Pursuant to Rule 17f-2 [17 CFR 270.17f-2]

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1. Investment Company Act File Number: 23271

 

 

 

 

 

Date examination completed:

811-

 

 

 

 

 

 

 

April 30, 2018

2. State identification Number:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AL

AK

 

AZ

AR

 

 

 

CA

CO

 

 

 

 

 

 

 

 

 

 

 

 

CT

DE 2340899

 

DC

FL

 

 

 

GA

HI

 

 

 

 

 

 

 

 

 

 

 

 

ID

IL

 

IN

IA

 

 

 

KS

KY

 

 

 

 

 

 

 

 

 

 

 

 

LA

ME

 

MD

MA

 

 

 

MI

MN

 

 

 

 

 

 

 

 

 

 

 

 

MS

MO

 

MT

NE

 

 

 

NV

NH

 

 

 

 

 

 

 

 

 

 

 

 

NJ

NM

 

NY

NC

 

 

 

ND

OH

 

 

 

 

 

 

 

 

 

 

 

 

OK

OR

 

PA

RI

 

 

 

SC

SD

 

 

 

 

 

 

 

 

 

 

 

 

TN

TX

 

UT

VT

 

 

 

VA

WA

 

 

 

 

 

 

 

 

 

 

 

WV

WI

 

WY

PUERTO RICO

 

 

 

 

 

 

 

 

 

 

 

 

 

Other (specify):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3. Exact name of investment company as specified in registration statement:

 

 

 

 

 

 

 

 

 

 

USAA ETF Trust

 

 

 

 

 

 

 

 

4. Address of principal executive office (number, street, city, state, zip code):

9800 Fredericksburg Road

 

 

 

 

 

 

 

 

 

 

 

 

 

 

San Antonio, Texas 78288

 

 

 

 

 

 

 

 

 

 

 

 

INSTRUCTIONS

This Form must be completed by investment companies that have custody of securities or similar investments.

Investment Company

1.All items must be completed by the investment company.

2.Give this Form to the independent public accountant who, in compliance with Rule 17f-2 under the Act and applicable state law, examines securities and similar investments in the custody of the investment company.

Accountant

3.Submit this Form to the Securities and Exchange Commission and appropriate state securities administrators when filing the certificate of accounting required by Rule 17f-2 under the Act and applicable state law. File the original and one copy with the Securities and Exchange Commission's principal office in Washington, D.C., one copy with the regional office for the region in which the investment company's principal business operations are conducted, and one copy with the appropriate state administrator(s), if applicable.

THIS FORM MUST BE GIVEN TO YOUR INDEPENDENT PUBLIC ACCOUNTANT

SEC 2198 (04-09)

SEC÷s Collection of Information

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. Filing of Form N-17f-2 is mandatory for an investment company that has custody of securities or similar investments. Rule 17f-2 under section 17(f) of the Investment Company Act of 1940 requires the investment company to retain an independent public accountant to verify the company÷s securities and similar investments by actual examination three times during each fiscal year. The accountant must prepare a certificate stating that the examination has occurred and describing the examination, and must transmit the certificate to the Commission with Form N-17f-2 as a cover sheet. The Commission uses the Form to ensure that the certificate is properly attributed to the investment company. The Commission estimates that the burden of completing Form N-17f-2 is approximately 1.0 hours per filing. Any member of the public may direct to the Commission any comments concerning the accuracy of the burden estimate of this Form, and any suggestions for reducing this burden. This collection of information has been reviewed by the Office of Management and Budget in accordance with the clearance requirements of 44 U.S.C. ▪ 3507. Responses to this collection of information will not be kept confidential.

2

Report of Independent Registered Public Accounting Firm

To the Board of Trustees of

USAA MSCI USA Value Momentum Blend Index ETF

USAA MSCI USA Small Cap Value Momentum Blend Index ETF

We have examined management's assertion, included in the accompanying Management Statement Regarding Compliance With Certain Provisions of the Investment Company Act of 1940, that the USAA MSCI USA Value Momentum Blend Index ETF and the USAA MSCI USA Small Cap Value Momentum Blend Index ETF

(the Funds) complied with the requirements of subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940 (the Act) as of April 30, 2018. Management is responsible for the Funds' compliance with those requirements. Our responsibility is to express an opinion on management's assertion about the Funds' compliance based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Funds' compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. Included among our procedures were the following tests performed as of April 30, 2018 and with respect to agreement of security purchases and sales, for the period from December 31,

2017 (the date of our last examination), through April 30, 2018:

•Confirmation of all securities held by institutions in book entry form (The Depository Trust Company);

•Confirmation of all securities hypothecated, pledged, placed in escrow or out for transfer with brokers, pledgees or transfer agents;

•Reconciliation of all such securities to the books and records of the Fund and the Custodian, State Street Bank;

•Confirmation of all open future positions with brokers; and

•Agreement of five security purchases and five security sales or maturities since inception from the books and records of each Fund to broker confirmations or by other appropriate auditing procedures where replies from brokers were not received.

We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Funds' compliance with specified requirements.

In our opinion, management's assertion that the USAA MSCI USA Value Momentum Blend Index ETF and the USAA MSCI USA Small Cap Value Momentum Blend Index ETF complied with the requirements of subsections (b) and (c) of rule 17f-2 of the Act as

Internal

of April 30, 2018, with respect to securities reflected in the investment accounts of the Funds are fairly stated, in all material respects.

This report is intended solely for the information and use of management and the Board of Trustees of the USAA MSCI USA Value Momentum Blend Index ETF and the USAA MSCI USA Small Cap Value Momentum Blend Index ETF and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

Ernst & Young LLP

San Antonio, Texas

September 7, 2018

Internal

Management Statement Regarding Compliance with Certain Provisions of the

Investment Company Act of 1940

September 7, 2018

We, as members of management of the USAA MSCI Emerging Markets Momentum Blend Index ETF and the USAA MSCI International Value Momentum Blend Index ETF (the Funds), are responsible for complying with the requirements of subsections (b) and (c) of Rule 17f-2, "Custody of Investments by Registered Management Investment Companies," of the Investment Company Act of 1940 ("the Act"). We are also responsible for establishing and maintaining effective internal controls over compliance with those requirements. We have performed an evaluation of the Funds' compliance with the requirements of subsections (b) and (c) of Rule 17f-2 as of December 31, 2017, and from October 24, 2017 (commencement of operations) through December 31, 2017.

Based on this evaluation, we assert that the Funds were in compliance with the requirements of subsections (b) and (c) of Rule 17f-2 of the Act as of December 31, 2017, and from October 24, 2017 (commencement of operations) through December 31, 2017, with respect to securities reflected in the investment account of the Funds.

USAA MSCI EMERGING MARKETS MOMENTUM BLEND INDEX ETF USAA MSCI INTERNATIONAL VALUE MOMENTUM BLEND INDEX ETF

By:

___/s/ Dan McNamara______________

Dan McNamara

President and Vice Chairman of the

Board of Trustees

__/s/ James De Vries_______________

James De Vries

Treasurer

Internal



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