CONL / GraniteShares ETF Trust - GraniteShares 2x Long COIN Daily ETF - Pengajuan SECLaporan Tahunan, Pernyataan Proksi

As filed with the Securities and Exchange Commission on August 25, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECUR

As filed with the Securities and Exchange Commission on August 25, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on July 16, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURIT

As filed with the Securities and Exchange Commission on July 16, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on July 07, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURIT

As filed with the Securities and Exchange Commission on July 07, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on June 02, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURIT

As filed with the Securities and Exchange Commission on June 02, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on May 06, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITI

As filed with the Securities and Exchange Commission on May 06, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on April 16, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURI

As filed with the Securities and Exchange Commission on April 16, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on March 18, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURI

As filed with the Securities and Exchange Commission on March 18, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

ANNUAL FINANCIAL STATEMENTS All Funds

March 13, 2025 Megan Miller Division of Investment Management U.S. Securities and Exchange Commission 3 World Financial Center New York, New York 10281 Re: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. Miller This correspondence is submitted in response to the Staff’s additional comments related to the June 30, 2024, Form N-CSR for GraniteShares

March 12, 2025

March 12, 2025 Kim McManus Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. McManus: On March 6, 2025, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long AAL Daily ETF, GraniteShares 1x Short

March 12, 2025

March 12, 2025 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long IONQ Daily ETF, Gra

March 12, 2025

March 12, 2025 Kim McManus Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. McManus: On March 6, 2025, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long ADBE Daily ETF, GraniteShares 2x Shor

GRANITESHARES FUNDS May 04, 2025

March 12, 2025 Kim McManus Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. McManus: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long ADBE Daily ETF, GraniteShares 2x

As filed with the Securities and Exchange Commission on March 05, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURI

As filed with the Securities and Exchange Commission on March 05, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

SUMMARY PROSPECTUS ALL FUNDS

February 26, 2025 Lisa Larkin Division of Investment Management U.S. Securities and Exchange Commission 100 G Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. Larkin: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares YieldBOOST QQQ ETF, GraniteShares Yield

SUMMARY PROSPECTUS ALL FUNDS

February 26, 2025 Kim McManus Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. McManus: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long AAL Daily ETF, GraniteShares 1

SUMMARY PROSPECTUS ALL FUNDS

February 26, 2025 Kim McManus Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. McManus: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long ADBE Daily ETF, GraniteShares

February 26, 2025

February 26, 2025 Kim McManus Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. McManus: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long ADBE Daily ETF, GraniteShares

SUMMARY PROSPECTUS ALL FUNDS

February 18, 2025 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On December 18, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of GraniteShares 2x Long IONQ Daily ETF,

As filed with the Securities and Exchange Commission on February 18, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on February 18, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on February 11, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on February 11, 2025 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

TAILORED SHAREHOLDER REPORTS

January 16, 2025 Megan Miller Division of Investment Management U.S. Securities and Exchange Commission 3 World Financial Center New York, New York 10281 Re: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Ms. Miller This correspondence is submitted in response to the Staff’s comments related to the June 30, 2024, Form N-CSR for GraniteShares ETF Trus

As filed with the Securities and Exchange Commission on December 11, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on December 11, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on December 11, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on December 11, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on November 08, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on November 08, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

GRANITESHARES FUNDS October [XX], 2024

October 22, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On June 25, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of its series, GraniteShares 2x Long ADBE Dail

GRANITESHARES FUNDS October [21], 2024

October 16, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On June 25, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of its series, GraniteShares 2x Long ADBE Dail

* * * * *

September 13, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: GraniteShares; File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On June 25, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of its series, GraniteShares 1.25x Long TSLA Daily ETF, GraniteShares 2x Long NVDA Dail

As filed with the Securities and Exchange Commission on September 03, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SE

As filed with the Securities and Exchange Commission on September 03, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on September 03, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SE

As filed with the Securities and Exchange Commission on September 03, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

GENERAL COMMENTS

August 29, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: GraniteShares ETF Trust (the “Trust” or the “Registrant”) File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On June 25, 2024, GraniteShares ETF Trust (the “Trust” or “Registrant”), on behalf of its series, GraniteShares 1.25x Long TSLA Da

GraniteShares ETF Trust 222 Broadway, 21st Floor New York, NY 10038

GraniteShares ETF Trust 222 Broadway, 21st Floor New York, NY 10038 July 31, 2024 Via Electronic Transmission U.

As filed with the Securities and Exchange Commission on March 15, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURI

As filed with the Securities and Exchange Commission on March 15, 2024 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

* * * * *

February 06, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: GraniteShares; File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On November 22, 2023, GraniteShares ETF Trust (the “Trust” or “Registrant”) filed a Registration Statement under the Securities Act of 1933 and the Investment Company Act

* * * * *

January 24, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: GraniteShares; File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On November 22, 2023, GraniteShares ETF Trust (the “Trust” or “Registrant”) filed a Registration Statement under the Securities Act of 1933 and the Investment Company Act o

January 22, 2024

January 22, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: GraniteShares; File Nos. 333-214796, 811-23214 Dear Mr. Bellacicco: On November 22, 2023, GraniteShares ETF Trust (the “Trust” or “Registrant”) filed a Registration Statement under the Securities Act of 1933 and the Investment Company Act o

AS FILED WITH THE SECURITIES AND EXCHANGE COMMISSION ON JANUARY [19], 2024

January 10, 2024 Christopher Bellacicco Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: GraniteShares ETF Trust; File Nos. 811-23214, 333-214796 Dear Mr. Bellacicco: On November 22, 2023, GraniteShares ETF Trust (the “Trust” or “Registrant”) filed a Registration Statement under the Securities Act of 1933 and the Investment Com

As filed with the Securities and Exchange Commission on December 08, 2022 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on December 08, 2022 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

As filed with the Securities and Exchange Commission on December 09, 2022 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on December 09, 2022 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

Notional Amount

GraniteShares ETF Trust Schedule of Investments GraniteShares 1.25x Long TSLA Daily ETF September 30, 2022 (Unaudited) Value Assets In Excess Of Other Liabilities - (100.00%) $ 440,880 NET ASSETS (100.00%) $ 440,880 TOTAL RETURN SWAP CONTRACTS Counterparty Reference Entity/Obligation(a) Currency Notional Amount Floating Rate Index Spread Termination Date Value Net Unrealized Appreciation Cowen Tes

Notional Amount

GraniteShares ETF Trust Schedule of Investments GraniteShares 1.75x Long AAPL Daily ETF September 30, 2022 (Unaudited) Value Assets In Excess Of Other Liabilities - (100.00%) $ 539,110 NET ASSETS (100.00%) $ 539,110 TOTAL RETURN SWAP CONTRACTS Counterparty Reference Entity/Obligation(a) Currency Notional Amount Floating Rate Index Spread Termination Date Value Net Unrealized Appreciation Cowen App

GraniteShares ETF Trust Notes to Quarterly Schedules of Investments September 30, 2022 (Unaudited)

GraniteShares ETF Trust Schedule of Investments GraniteShares XOUT U.S. Large Cap ETF September 30, 2022 (Unaudited) Investments Shares Value COMMON STOCKS - 99.89% Air Freight & Logistics - 0.67% CH Robinson Worldwide, Inc. 442 $ 42,569 United Parcel Service, Inc., Class B 3,094 499,806 Total Air Freight & Logistics 542,375 Automobiles - 3.73% Tesla, Inc.(a) 11,185 2,966,821 Banks - 0.14% M&T Ban

Notional Amount

GraniteShares ETF Trust Schedule of Investments GraniteShares 1.5x Long COIN Daily ETF September 30, 2022 (Unaudited) Value Assets In Excess Of Other Liabilities - (100.00%) $ 879,562 NET ASSETS (100.00%) $ 879,562 TOTAL RETURN SWAP CONTRACTS Counterparty Reference Entity/Obligation(a) Currency Notional Amount Floating Rate Index Spread Termination Date Value Net Unrealized Appreciation Cowen Coin

Notional Amount

GraniteShares ETF Trust Schedule of Investments GraniteShares 1x Short TSLA Daily ETF September 30, 2022 (Unaudited) Value Assets In Excess Of Other Liabilities - (100.

Number of

GraniteShares ETF Trust Consolidated Schedule of Investments GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF September 30, 2022 (Unaudited) Investments Principal Amount Value UNITED STATES TREASURY OBLIGATIONS - 90.

Level 1

GraniteShares ETF Trust Schedule of Investments GraniteShares HIPS U.S. High Income ETF September 30, 2022 (Unaudited) Investments Shares Value COMMON STOCKS - 48.37% Capital Markets - 14.61% Ares Capital Corp. 37,771 $ 637,574 Bain Capital Specialty Finance, Inc. 50,208 602,496 Barings BDC, Inc. 71,105 588,038 BlackRock TCP Capital Corp. 57,747 631,175 Carlyle Secured Lending, Inc. 55,687 637,059

As filed with the Securities and Exchange Commission on August 01, 2022 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECUR

8-A12B 1 form8-a12b.htm As filed with the Securities and Exchange Commission on August 01, 2022 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 GraniteShares ETF Trust (Exact name of registrant as specified in its charter) Delaware See list be

GraniteShares ETF Trust Notes to Quarterly Schedules of Investments March 31, 2022 (Unaudited)

GraniteShares ETF Trust Consolidated Schedule of Investments GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF March 31, 2022 (Unaudited) Principal Investments Amount Value UNITED STATES TREASURY OBLIGATIONS - 85.

GraniteShares ETF Trust Notes to Quarterly Schedules of Investments March 31, 2022 (Unaudited)

GraniteShares ETF Trust Schedule of Investments GraniteShares HIPS U.S. High Income ETF March 31, 2022 (Unaudited) Investments Shares Value COMMON STOCKS - 47.93% Capital Markets - 15.49% Ares Capital Corp. 37,122 $ 777,706 Bain Capital Specialty Finance, Inc. 49,339 769,195 Barings BDC, Inc. 69,881 722,570 BlackRock TCP Capital Corp. 56,755 811,596 Goldman Sachs BDC, Inc. 39,529 775,164 Golub Cap

GraniteShares ETF Trust Notes to Quarterly Schedules of Investments March 31, 2022 (Unaudited)

GraniteShares ETF Trust Schedule of Investments GraniteShares XOUT U.S. Large Cap ETF March 31, 2022 (Unaudited) Investments Shares Value COMMON STOCKS - 99.88% Air Freight & Logistics - 0.95% Expeditors International of Washington, Inc. 773 $ 79,743 FedEx Corp. 1,206 279,056 United Parcel Service, Inc., Class B 3,893 834,892 Total Air Freight & Logistics 1,193,691 Automobiles - 4.13% Tesla, Inc.(

GraniteShares ETF Trust Notes to Quarterly Schedules of Investments September 30, 2021 (Unaudited)

GraniteShares ETF Trut Schedules of Investments GraniteShares HIPS U.S. High Income ETF September 30, 2021 (Unaudited) Investments Shares Value COMMON STOCKS - 47.96% Capital Markets - 15.87% AllianceBernstein Holding LP(a) 17,584 $ 871,814 Apollo Global Management, Inc. 12,188 750,659 Ares Capital Corp. 35,790 727,611 Artisan Partners Asset Management, Inc., Class A 11,815 577,990 Bain Capital Sp

GraniteShares ETF Trust Notes to Quarterly Schedules of Investments September 30, 2021 (Unaudited)

GraniteShares XOUT U.S. Large Cap ETF September 30, 2021 (Unaudited) Investments Shares Value COMMON STOCKS - 99.89% Aerospace & Defense - 0.07% HEICO Corp. 668 $ 88,089 Air Freight & Logistics - 0.94% Expeditors International of Washington, Inc. 836 99,593 FedEx Corp. 1,315 288,366 United Parcel Service, Inc., Class B 4,306 784,123 Total Air Freight & Logistics 1,172,082 Auto Components - 0.16% A

Number of

GraniteShares ETF Trust Consolidated Schedule of Investments GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF September 30, 2021 (Unaudited) Investments Principal Amount Value UNITED STATES TREASURY OBLIGATIONS - 87.

GraniteShares ETF Trust

GraniteShares ETF Trust Schedule of Investments GraniteShares HIPS U.S. High Income ETF March 31, 2021 (Unaudited) Investments Shares Value COMMON STOCKS - 45.64% Capital Markets - 14.62% AllianceBernstein Holding LP(a)(b) 10,728 $ 429,014 Apollo Global Management, Inc. 7,436 349,566 Ares Capital Corp. 21,814 408,140 Artisan Partners Asset Management, Inc., Class A 7,196 375,415 Bain Capital Speci

GraniteShares ETF Trust

GraniteShares ETF Trust Schedule of Investments GraniteShares XOUT U.S. Large Cap ETF March 31, 2021 (Unaudited) Investments Shares Value COMMON STOCKS - 99.93% Aerospace & Defense - 0.22% HEICO Corp. 624 $ 78,499 TransDigm Group, Inc.(a) 274 161,090 Total Aerospace & Defense 239,589 Air Freight & Logistics - 1.13% CH Robinson Worldwide, Inc. 637 60,789 Expeditors International of Washington, Inc.

Principal

GraniteShares ETF Trust Consolidated Schedule of Investments GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF March 31, 2021 (Unaudited) Investments Principal Amount Value UNITED STATES TREASURY OBLIGATIONS - 91.

GraniteShares ETF Trust

GraniteShares ETF Trust Schedule of Investments GraniteShares XOUT U.S. Large Cap ETF September 30, 2020 (Unaudited) Investments Shares Value COMMON STOCKS – 99.9% Aerospace & Defense – 0.9% Boeing Co. (The) 2,009 $ 332,007 Lockheed Martin Corp. 984 377,148 Total Aerospace & Defense 709,155 Air Freight & Logistics – 0.8% CH Robinson Worldwide, Inc. 449 45,883 Expeditors International of Washington

GraniteShares ETF Trust

GraniteShares ETF Trust Consolidated Schedule of Investments GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF September 30, 2020 (Unaudited) Investments Principal Value UNITED STATES TREASURY OBLIGATIONS – 95.

GraniteShares ETF Trust

GraniteShares ETF Trust Schedule of Investments GraniteShares HIPS US High Income ETF September 30, 2020 (Unaudited) Investments Shares Value COMMON STOCKS – 57.

-

GraniteShares ETF Trust Schedule of Investments GraniteShares XOUT U.S. Large Cap ETF March 31, 2020 (Unaudited) Investments Shares Value COMMON STOCKS – 98.1% Aerospace & Defense – 2.0% Boeing Co. (The) 679 $ 101,266 General Dynamics Corp. 345 45,647 Howmet Aerospace, Inc.* 525 8,432 Huntington Ingalls Industries, Inc. 49 8,928 Northrop Grumman Corp. 193 58,392 Raytheon Co. 323 42,361 United Tech

-

GraniteShares ETF Trust Consolidated Schedule of Investments GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF March 31, 2020 (Unaudited) Investments Principal Value UNITED STATES TREASURY OBLIGATIONS – 88.

-

GraniteShares ETF Trust Schedule of Investments GraniteShares HIPS US High Income ETF March 31, 2020 (Unaudited) Investments Shares Value COMMON STOCKS – 55.

EX-99.25

EX-99.25 2 ruleprovisionnotice.htm NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES NYSE Arca hereby notifies the SEC of its intention to remove the entire class of the stated securities from listing and registration on the Exchange at the opening of business on December 03, 2019, pursuant to the provisions of Rule 12d2-2 (a). [ X ] 17 CFR 240.12d2-2(a)(3) That on

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act I, William Rhind, certify that: 1.

Graniteshares Etf Trust

N-Q 1 formnq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23214 GraniteShares ETF Trust (Exact name of registrant as specified in charter) 205 Hudson Street, 7th floor New York, New York 10013 (Address of principal executive offices) (Z

Graniteshares Etf Trust 8-A12B - -

As filed with the Securities and Exchange Commission on September 24, 2019 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

Graniteshares Etf Trust CORRESP - -

CORRESP 1 filename1.htm September 19, 2019 VIA EDGAR correspondence Ryan Sutcliff, Esq. United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com W. Thomas Conner Shareholder +1 202 312 3331 [email protected] Re: GraniteShares ETF Trust (th

Graniteshares Etf Trust CORRESP - -

September 18, 2019 VIA EDGAR correspondence Ryan Sutcliff, Esq. United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: GraniteShares ETF Trust (the ?Registrant?) Post-Effective Amendment No. 10 (File Nos. 333-214796, 811-23214) Dear Mr. Sutcliff: We are writing in response to comments provided telephonically on September 18, 201

Graniteshares Etf Trust CORRESP - -

CORRESP 1 filename1.htm August 20, 2019 Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com VIA EDGAR correspondence Ryan Sutcliff, Esq. United States Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 W. Thomas Conner Shareholder +1 202 312 3331 [email protected] Re: GraniteShares ETF Trust (the “

Graniteshares Etf Trust CORRESP - -

July 11, 2019 via EDGAR Transmission U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: GraniteShares ETF Trust Post-Effective Amendment No. 10 under the Securities Act of 1933 and Amendment No. 13 under the Investment Company Act of 1940 File Nos. 333-214796 and 811-23214 To the Commission: On behalf of GraniteShares ETF Trust (the “Registrant”) we are transmitting

Graniteshares Etf Trust N-Q - Quarterly Schedule of Portfolio Holdings -

N-Q 1 formnq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23214 GraniteShares ETF Trust (Exact name of registrant as specified in charter) 205 Hudson Street, 7th floor New York, New York 10013 (Address of principal executive offices) (Z

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act I, William Rhind, certify that: 1.

Graniteshares Etf Trust CORRESP

March 27, 2019 via EDGAR Transmission U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Lisa N. Larkin, Esq. Division of Investment Management Re: GraniteShares ETF Trust Post-Effective Amendment No. 9 under the Securities Act of 1933 and Amendment No. 12 under the Investment Company Act of 1940 File Nos. 333-214796 and 811-23214 To the Commission: On behalf of Gr

Graniteshares Etf Trust CORRESP

March 27, 2019 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: GraniteShares ETF Trust File Nos. 333-214796 and 811-23214 Request for Acceleration Ladies and Gentlemen: Pursuant to the requirements of Rule 461 under the Securities Act of 1933, as amended, GraniteShares ETF Trust (the “Registrant”), on behalf of its n

Graniteshares Etf Trust CORRESP

CORRESP 1 filename1.htm Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com March 18, 2019 Nathaniel Segal Counsel +1 312 609 7747 [email protected] VIA EDGAR CORRESPONDENCE Lisa N. Larkin, Esq. Disclosure Review Office Division of Investment Management United States Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: GraniteShar

Graniteshares Etf Trust AW

GraniteShares ETF Trust December 21, 2018 via EDGAR Transmission U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Dominic J. Minore, Esq.; Kim L. Murray, Research Specialist, Investment Management, Disclosure Review and Accounting Office Re: GraniteShares ETF Trust (the “Registrant”) File Nos. 333-214796, 811-23214 Post-Effective Amendment No. 6 to the Registrant

Certifications pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act I, William Rhind, certify that: 1.

Graniteshares Etf Trust N-Q (Quarterly Schedule of Portfolio Holdings)

N-Q 1 formnq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23214 GraniteShares ETF Trust (Exact name of registrant as specified in charter) 205 Hudson Street, 7th floor New York, New York 10013 (Address of principal executive offices) (Z

Certifications pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.

EX-99 2 ex99.htm Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act I, William Rhind, certify that: 1. I have reviewed this report on Form N-Q of the GraniteShares ETF Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light

Graniteshares Etf Trust - N-Q

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23214 GraniteShares ETF Trust (Exact name of registrant as specified in charter) 205 Hudson Street, 7th floor New York, New York 10013 (Address of principal executive offices) (Zip code) William

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act

EX-99.CERT 2 ex99-cert.htm EX-99.CERT Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act I, William Rhind, certify that: 1. I have reviewed this report on Form N-Q of the GraniteShares ETF Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the stat

Graniteshares Etf Trust N-Q (Quarterly Schedule of Portfolio Holdings)

N-Q 1 formnq.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23214 GraniteShares ETF Trust (Exact name of registrant as specified in charter) 205 Hudson Street, 7th floor New York, New York 10013 (Address of principal executive offices) (Z

Graniteshares Etf Trust CORRESP

CORRESP 1 filename1.htm December 18, 2017 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street N.E. Washington, D.C. 20549 Attn: Valerie J. Lithotomos Re: GraniteShares ETF Trust (the “Registrant”) (File Nos. 333-214796; 811-23214) Registration Statement on Form N-14 To the Commission: On behalf of the Registrant, this letter is in response to the commen

As filed with the Securities and Exchange Commission on December 13, 2017 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SEC

As filed with the Securities and Exchange Commission on December 13, 2017 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act

EX-99.CERT 2 ex99-cert.htm CERTIFICATION GraniteShares ETF Trust N-Q EX-99.CERT Certification Pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act I, William Rhind, certify that: 1. I have reviewed this report on Form N-Q of the GraniteShares ETF Trust; 2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state

Graniteshares Etf Trust - QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-Q QUARTERLY SCHEDULE OF PORTFOLIO HOLDINGS OF REGISTERED MANAGEMENT INVESTMENT COMPANY Investment Company Act file number 811-23214 GraniteShares ETF Trust (Exact name of registrant as specified in charter) 30 Vesey Street, 9th floor New York, New York 10007 (Address of principal executive offices) (Zip code) William Rh

Graniteshares Etf Trust CORRESP

November 13, 2017 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street N.E. Washington, D.C. 20549 Attn: Lisa N. Larkin, Esq. Re: GraniteShares ETF Trust (the “Registrant”) (File No. 333-220960) Registration Statement on Form N-14 To the Commission: On behalf of the Registrant, this letter is in response to the comments provided telephonically by the sta

Second Amendment to Distribution Agreement between GraniteShares ETF Trust and Distributor (3)

GraniteShares ETF Trust N-14 Exhibit 99.7(b) SECOND AMENDMENT TO ETF DISTRIBUTION AGREEMENT This second amendment ("Amendment") to the ETF Distribution Agreement dated May 31, 2017 (the "Agreement”), by and between GraniteShares ETF Trust (the “Trust”), and Foreside Fund Services, LLC (“Distributor”), is entered into as of October 13, 2017 (the "Effective Date"). WHEREAS, the Trust and Distributor

Schedule II, as amended October 11, 2017, to the Custody Agreement dated March 6, 2017 between the Registrant and The Bank of New York Mellon (3)

GraniteShares ETF Trust N-14 Exhibit 99.9(b) SCHEDULE II TO THE CUSTODY AGREEMENT, dated as of March 6, 2017 between GraniteShares ETF Trust (the ?Trust?) and The Bank of New York Mellon (?Custodian?). AS REVISED October 11, 2017. FUNDS GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF GraniteShares S&P GSCI Commodity Broad Strategy No K-1 ETF GraniteShares HIPS US High Income ETF IN WIT

Opinion and Consent of Vedder Price P.C., regarding the legality of securities being issued, is filed herewith.

GraniteShares ETF Trust N-14 Exhibit 99.11 Chicago New York Washington, DC London San Francisco Los Angeles Singapore vedderprice.com October 13, 2017 GraniteShares ETF Trust 30 Vesey Street, 9th Floor New York, NY 10007 Ladies and Gentlemen: We have acted as counsel to GraniteShares ETF Trust, a Delaware statutory trust (the “Trust”), in connection with the filing with the Securities and Exchange

Consent of independent registered public accountants, KPMG LLP, is filed herewith.

GraniteShares ETF Trust N-14 Exhibit 99.15 KPMG LLP 345 Park Avenue New York, NY 10154-0102 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM The Board of Trustees GraniteShares ETF Trust We consent to the references to our firm under the captions “Other Service Providers”, “Fund Service Providers” and “Independent Registered Public Accounting Firm” in the Combined Proxy Statement and Prosp

Appendix A, as amended October 11, 2017, to the Transfer Agency and Service Agreement between GraniteShares ETF Trust and Transfer Agent (3)

GraniteShares ETF Trust N-14 Exhibit 99.13(d) APPENDIX A TO THE TRANSFER AGENCY AND SERVICES AGREEMENT, dated as of March 6, 2017 between GRANITESHARES ETF TRUST (the “Trust”) and The Bank of New York Mellon (“Bank”). AS REVISED October 11, 2017 FUNDS GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF GraniteShares S&P GSCI Commodity Broad Strategy No K-1 ETF GraniteShares HIPS US High In

(1)(b) Amendment No. 1 dated as of October 11, 2017 to the Investment Advisor yAgreement dated April 25, 2017 between the Registrant and GraniteShares Advisors LLC. (4)

EX-99.6(B) 2 ex99-6b.htm AMENDMENT NO. 1 DATED AS OF OCTOBER 11, 2017 TO THE INVESTMENT ADVISORY AGREEMENT GraniteShares ETF Trust N-14 Exhibit 99.6(b) AMENDMENT No. 1 INVESTMENT ADVISORY AGREEMENT This Amendment No. 1 (this “Amendment”) to the Investment Advisory Agreement, effective April 25, 2017 (the “Agreement”), by and between GraniteShares ETF Trust, a Delaware trust (the “Trust”), on behal

As filed with the U.S. Securities and Exchange Commission on October 13, 2017

N-14 1 gstrust-n14101317.htm INITIAL REGISTRATION STATEMENT As filed with the U.S. Securities and Exchange Commission on October 13, 2017 1933 Act Registration No. UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☐ Pre-Effective Amendment No. ☐ Post-Effective Amendment No. (Check appropriate box or boxes.) GRA

Consent of independent registered public accountants, Cohen & Company, Ltd., is filed herewith.

GraniteShares ETF Trust N-14 Exhibit 99.14 CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation by reference in this Registration Statement on Form N-14 of our report dated January 30, 2017, relating to the financial statements and financial highlights of Master Income ETF, a series of ETF Series Solutions, for the year ended November 30, 2016, and to the

Exhibit A, as amended October 11, 2017, to the Fund Administration and Accounting Agreement dated March 6, 2017 between the Registrant and The Bank of New York Mellon (3)

GraniteShares ETF Trust N-14 Exhibit 99.13(b) EXHIBIT A TO THE FUND ADMINISTRATION AND ACCOUNTING AGREEMENT, dated as of March 6, 2017 between GRANITESHARES ETF TRUST (the ?Trust?) and The Bank of New York Mellon (?BNYM?). AS REVISED October 11, 2017. FUNDS GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF GraniteShares S&P GSCI Commodity Broad Strategy No K-1 ETF GraniteShares HIPS US H

Form of Opinion and Consent of Vedder Price P.C., regarding certain tax matters, is filed herewith.

EX-99.12 7 ex99-12.htm FORM OF TAX OPINION GraniteShares ETF Trust N-14 Exhibit 99.12(b) [Form of Tax Opinion] , 2017 Master Income ETF 615 East Michigan Street Milwaukee, Wisconsin 53202 GraniteShares HIPS US High Income ETF 30 Vesey Street, 9th Floor New York, New York 10007 Re: Reorganization of Master Income ETF into GraniteShares HIPS US High Income ETF Ladies and Gentlemen: You have requeste

(2)(b) Expense Limitation Agreement between the Registrant and GraniteShares Advisors effective as of October 11, 2017. (4)

GraniteShares ETF Trust N-14 Exhibit 99.13(e) EXPENSE LIMITATION AGREEMENT GRANITESHARES ETF TRUST This Agreement is made and entered into effective as of October 11, 2017, by and between the GraniteShares HIPS US High Income ETF (the ?HIPS Fund?) a series of shares of GraniteShares ETF Trust, a Delaware statutory trust (the ?Trust?), and GraniteShares Advisors LLC, a Delaware limited liability co

Schedule A, amended and restated as of October 11, 2017, to the Distribution and Service Plan dated March 16, 2017 is filed herewith.

GraniteShares ETF Trust N-14 Exhibit 99.10(b) SCHEDULE A Amended and Restated as of October 11, 2017 GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF GraniteShares S&P GSCI Commodity Broad Strategy No K-1 ETF GraniteShares HIPS US High Income ETF

Graniteshares Etf Trust CORRESP

October 13, 2017 Via EDGAR Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 Re: GraniteShares ETF Trust (the “Registrant”) Registration Statement on Form N-14 To the Commission: On behalf of the Registrant, electronically transmitted herewith is the Registrant’s Registration Statement on Form N-14 relating to the issuance by GraniteShares HIPS US High Income ETF, a serie

As filed with the Securities and Exchange Commission on May 18, 2017 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITI

As filed with the Securities and Exchange Commission on May 18, 2017 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

(4) Investment Advisory Agreement between GraniteShares GSCI Cayman Limited (a wholly owned subsidiary of GraniteShares ETF Trust) and GraniteShares Advisor LLC (3)

GraniteShares EFT Trust N-1A/A Exhibit (d)(4) INVESTMENT ADVISORY AGREEMENT GraniteShares GSCI Cayman Limited Maples Corporate Services Limited, PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands March 30, 2017 GraniteShares Advisors LLC 30 Vesey Street, 9th Floor New York, NY 10007 Dear Sirs: We, the GraniteShares GSCI Cayman Limited, herewith confirm our agreement with you as follows: 1.

May 17, 2017

CORRESP 1 filename1.htm May 17, 2017 VIA EDGAR Lisa N. Larkin U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: GranitShares ETF Trust Registration Statement on Form N-1A (Amendment No. 3) File No. 333-214796; 811-23214 Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, GraniteSh

As filed with the Securities and Exchange Commission on May 17, 2017 Securities Act File No. 333-214796 Investment Company Act File No. 811-23214 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

As filed with the Securities and Exchange Commission on May 17, 2017 Securities Act File No.

(3) Investment Advisory Agreement between GraniteShares BCOM Cayman Limited (a wholly owned subsidiary of GraniteShares ETF Trust) and GraniteShares Advisor LLC (3)

GraniteShares EFT Trust N-1A/A Exhibit (d)(3) INVESTMENT ADVISORY AGREEMENT GraniteShares BCOM Cayman Limited Maples Corporate Services Limited, PO Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands March 30, 2017 GraniteShares Advisors LLC 30 Vesey Street, 9th Floor New York, NY 10007 Dear Sirs: We, the GraniteShares BCOM Cayman Limited, herewith confirm our agreement with you as follows: 1.

1301 K Street, N.W.

1301 K Street, N.W. Suite 1000 - East Tower Washington, D.C. 20005-3373 Tel +1 202 414 9200 Fax +1 202 414 9299 reedsmith.com W. Thomas Conner Admitted to practice in Washington, D.C., Virginia and Massachusetts Direct Phone: +1 804 344 3441 Email: [email protected] May 17, 2017 VIA EDGAR Lisa N. Larkin U.S. Securities & Exchange Commission Division of Investment Management 100 F Street, NE Wa

Fund Administration and Accounting Agreement between GraniteShares ETF Trust and Administrator (2)

GraniteShares ETF Trust - N-1A/A Exhibit (h)(1) EXECUTION FUND ADMINISTRATION AND ACCOUNTING AGREEMENT THIS AGREEMENT is made as of March 6, 2017 by and between GraniteShares ETF Trust (hereinafter the ?Trust?), on behalf of each series of the Trust listed on Appendix A hereto as updated from time to time (each a ?Fund?, and collectively the ?Funds?) having its principal office and place of business at 30 Vesey Street, 9th Floor, New York, New York 10007 and The Bank of New York Mellon, a New York corporation authorized to do a banking business (?BNY Mellon?).

Consent of Independent Registered Public Accounting Firm

EX-99.(J) 11 ex99-j.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM GraniteShares ETF Trust N-1A/A Exhibit (j) CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM The Board of Trustees GraniteShares ETF Trust We consent to the use of our report dated May 4, 2017, included herein, with respect to the consolidated statements of assets and liabilities (in organization) of GraniteSha

Custody Agreement between GraniteShares ETF Trust and Custodian (2)

GraniteShares ETF Trust - N-1A/A Exhibit (g) Execution CUSTODY AGREEMENT AGREEMENT, dated as of March 6, 2017 between GraniteShares ETF Trust, a Delaware statutory trust, having its principal office and place of business at 30 Vesey Street, 9th Floor, New York, New York, 10007 (the ?Trust?) on behalf of each series of each Series of the Trust listed in Schedule 2 hereto as updated from time to time (each, a ?Fund? and collectively, the ?Funds?) and The Bank of New York Mellon, a New York corporation authorized to do a banking business, having its principal office and place of business at 225 Liberty Street, New York, New York 10286 (?Custodian?).

Bylaws of GraniteShares ETF Trust, incorporated by reference to Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on May 5, 2017.

GraniteShares ETF Trust N-1A/A Exhibit (b) GRANITESHARES ETF TRUST (the ?Trust?) BYLAWS Dated March 16, 2017 ARTICLE I DEFINITIONS All capitalized terms have the respective meanings given them in the Declaration of Trust of GraniteShares ETF Trust (the ?Declaration of Trust?), dated November 21, 2016.

1301 K Street, N.W.

1301 K Street, N.W. Suite 1000 - East Tower Washington, D.C. 20005-3373 Tel +1 202 414 9200 Fax +1 202 414 9299 reedsmith.com W. Thomas Conner Admitted to practice in Washington, D.C., Virginia and Massachusetts Direct Phone: +1 804 344 3441 Email: [email protected] May 5, 2017 VIA EDGAR Lisa N. Larkin U.S. Securities & Exchange Commission Division of Investment Management 100 F Street, NE Was

Form of Authorized Participant Agreement (2)

GraniteShares ETF Trust - N-1A/A Exhibit (e)(2) FORM OF AUTHORIZED PARTICIPANT AGREEMENT GRANITESHARES ETF TRUST This Authorized Participant Agreement (the “Agreement”) is entered into by and between Foreside Fund Services, LLC (the “Distributor”) and (the “Participant”) and is subject to acceptance by [Name of Transfer Agent/Index Receipt Agent] (the “[Transfer Agent/Index Receipt Agent]”), and is further subject to acknowledgement and agreement by GraniteShares ETF Trust (the “Trust”), a series trust offering a number of portfolios of securities (each a “Fund” and collectively the “Funds”), solely with respect to Sections 4(c) and 12(c) herein.

Code of Ethics of Distributor (2)

EX-99.(P)(3) 16 ex99-p3.htm CODE OF ETHICS GraniteShares ETF Trust - N-1A/A Exhibit (p)(3) Code of Ethics Code of Ethics INTRODUCTION 1 1. STANDARDS OF PROFESSIONAL CONDUCT 2 (a) Fiduciary Duties 2 (b) Compliance with Laws 2 (c) Corporate Culture 2 (d) Professional Misconduct 3 (e) Disclosure of Conflicts 3 (f) Undue Influence 3 (g) Confidentiality and Protection of Material Nonpublic Information

As filed with the Securities and Exchange Commission on May 5, 2017 Securities Act File No. 333-214796 Investment Company Act File No. 811-23214 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

N-1A/A 1 gstrust-n1aa050517.htm FORM N-1A/A As filed with the Securities and Exchange Commission on May 5, 2017 Securities Act File No. 333-214796 Investment Company Act File No. 811-23214 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ☒ Pre-Effective Amendment No. 2 ☒ Post-Effective Amendment No. ☐ and/or REGISTRATI

Form of Initial Capital Agreement, incorporated by reference to Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on May 5, 2017.

GraniteShares ETF Trust - N-1A/A Exhibit (l) FORM OF INITIAL CAPITAL AGREEMENT THIS INITIAL CAPITAL AGREEMENT is entered into as of April 21, 2017 by and between GraniteShares Advisors LLC, with its principal office at 30 Vesey Street, 9th Floor, New York, New York 10007 (?Purchaser?), and GraniteShares ETF Trust, a Delaware statutory trust, with its principal office at 30 Vesey Street, 9th Floor, New York, New York (the ?Trust?).

Transfer Agency and Service Agreement between GraniteShares ETF Trust and Transfer Agent (2)

GraniteShares ETF Trust - N-1A/A Exhibit (h)(2) EXECUTION TRANSFER AGENCY AND SERVICE AGREEMENT THIS AGREEMENT is made as of the 6th day of March, 2017, by and between GRANITESHARES ETF TRUST (hereinafter the “Trust”) on behalf of each series of the Trust listed on Appendix A hereto as updated from time to time (each, a “Fund,” and collectively, the “Funds”), having its principal office and place of business at 30 Vesey Street, 9th Floor, New York, New York, 10007 and THE BANK OF NEW YORK MELLON, a New York corporation authorized to do a banking business having its principal office and place of business at One Wall Street, New York, New York 10286 (the “Bank”).

(2) (a) Expense Limitation Agreement between GraniteShares ETF Trust and GraniteShares Advisors LLC effective as of April 25, 2017. (2)

GraniteShares ETF Trust - N-1A/A Exhibit (d) (2) EXPENSE LIMITATION AGREEMENT GRANITESHARES ETF TRUST This Agreement is made and entered into effective as of April 25, 2017, by and between the GraniteShares Bloomberg Commodity Broad Strategy No K-1 ETF (the “BCOM Fund”) and the GraniteShares S&P GSCI Commodity Broad Strategy No K-1 ETF (the “GSCI Fund” and, collectively with the BCOM Fund, the “Funds,” and each, a “Fund”), each a series of shares of GraniteShares ETF Trust, a Delaware statutory trust (the “Trust”), and GraniteShares Advisors LLC, a Delaware limited liability company (the “Advisor”).

Distribution Agreement between GraniteShares ETF Trust and Distributor (2)

GraniteShares ETF Trust - N-1A/A Exhibit (e)(1) ETF DISTRIBUTION AGREEMENT This Distribution Agreement (the ?Agreement?) is made this 20 day of January 2017, by and between GraniteShares ETF Trust, a Delaware Statutory Trust (the ?Trust?) having its principal place of business at 30 Vesey Street 9th Floor, New York, New York 10007, and Foreside Fund Services, LLC, a Delaware limited liability company (the ?Distributor?) having its principal place of business at Three Canal Plaza, Suite 100, Portland, ME 04101.

Opinion and Consent of Counsel

EX-99.(I) 10 ex99-i.htm LEGAL OPINION GraniteShares ETF Trust - N-1A/A Exhibit (i) W. Thomas Conner Admitted to practice in Washington, D.C., Virginia and Massachusetts Direct Phone: +1 804 344 3441 Email: [email protected] 1301 K Street, N.W. Suite 1000 - East Tower Washington, D.C. 20005-3373 Tel +1 202 414 9200 Fax +1 202 414 9299 reedsmith.com May 3, 2017 GraniteShares ETF Trust 30 Vesey S

Code of Ethics of GraniteShares ETF Trust, incorporated by reference to Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on May 5, 2017.

GraniteShares ETF Trust - N-1A/A Exhibit (p)(1) GRANITESHARES ETF TRUST CODE OF ETHICS This Code of Ethics (the ?Code?) has been adopted by GraniteShares ETF Trust (the ?Trust?) in compliance with Rule 17j-1 under the Investment Company Act of 1940 (the ?Act?) (unless specifically identified, Rule 17j-1 is referred to as the ?Rule?).

Form of Distribution and Service Plan, incorporated by reference to Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on May 5, 2017.

EX-99.(M) 13 ex99-m.htm FORM OF DISTRIBUTION AND SERVICE PLAN GraniteShares ETF Trust - N-1A/A Exhibit (m) GRANITESHARES ETF TRUST FORM OF DISTRIBUTION AND SERVICE PLAN 1. The Trust. GraniteShares ETF Trust (the “Trust”) is an open-end management investment company registered as such under the Investment Company Act of 1940, as amended (the “1940 Act”), and organized as a series trust (each such s

(1) (a) Investment Advisory Agreement between GraniteShares ETF Trust and GraniteShares Advisors LLC (2)

GraniteShares ETF Trust - N-1A/A Exhibit (d)(1) INVESTMENT ADVISORY AGREEMENT This Agreement is made and entered into as of April 25, 2017, by and between GraniteShares ETF Trust, a Delaware trust (the “Trust”), on behalf of each fund set forth on Appendix A, each a series of shares of the Trust (each a “Fund” and collectively the “Funds”), and GraniteShares Advisors LLC, a Delaware limited liability company (the “Adviser”).

Code of Ethics of the GraniteShares Advisors LLC, incorporated by reference to Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on May 5, 2017.

GraniteShares ETF Trust - N-1A/A Exhibit (p)(2) 1. CODE OF ETHICS Introduction Pursuant to rules established by the U.S. Securities and Exchange Commission (the “SEC”), it is unlawful for certain persons of GraniteShares, in connection with the purchase or sale by such persons of securities held or to be acquired by a Client account: ● To employ any device, scheme or artifice to defraud; ● To make

As filed with the Securities and Exchange Commission on January 26, 2017 Securities Act File No. 333-214796 Investment Company Act File No. 811-23214 U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

As filed with the Securities and Exchange Commission on January 26, 2017 Securities Act File No.

1301 K Street, N.W.

1301 K Street, N.W. Suite 1000 - East Tower Washington, D.C. 20005-3373 Tel +1 202 414 9200 Fax +1 202 414 9299 reedsmith.com W. Thomas Conner Direct Phone: +1 804 344 3441 Email: [email protected] January 26, 2017 VIA EDGAR Lisa N. Larkin U.S. Securities & Exchange Commission Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: GraniteShares ETF Trust Registration State

Certificate of Trust of GraniteShares ETF Trust, incorporated by reference to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on November 23, 2016.

EX-99.(A)(1) 3 ex-99a1.htm CERTIFICATE OF TRUST GraniteShares ETF Trust - N-1A Exhibit (A) (I)

As filed with the Securities and Exchange Commission on November 23, 2016 Securities Act File No. 333-______ Investment Company Act File No. 811-_______ U.S. SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A

As filed with the Securities and Exchange Commission on November 23, 2016 Securities Act File No.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940

N-8A 1 gstrust-n8a112316.htm INITIAL NOTIFICATION OF REGISTRATION UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940 The undersigned investment company hereby notifies the Securities and Exchange Commission that it registers under and pursuant to the provisions of Sectio

W. Thomas Conner

W. Thomas Conner Admitted to practice in Washington, D.C.,Virginia and Massachusetts Direct Phone: 1.202.414.9208 Email: [email protected] Reed Smith LLP 1301 K Street, N.W. Suite 1000 - East Tower Washington, D.C. 20005-3373 Tel +1 202 414 9200 Fax +1 202 414 9299 reedsmith.com November 23, 2016 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington DC 10549 GraniteShares

Declaration of Trust of GraniteShares ETF Trust, incorporated by reference to the Registrant’s Registration Statement on Form N-1A (File No. 333-214796 and 811-23214) filed with the Securities and Exchange Commission on November 23, 2016.

GraniteShares ETF Trust - N-1A Exhibit (A) (2) DECLARATION OF TRUST of GRANITESHARES ETF TRUST Dated as of November 21, 2016 (A Delaware Statutory Trust) TABLE OF CONTENTS Page ARTICLE 1.