BNY
Mellon
ETF
Trust
ANNUAL
REPORT
October
31,
2023
BNY
Mellon
Sustainable
US
Equity
ETF
Contents
The
Fund
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The
views
expressed
herein
are
current
to
the
date
of
this
report.
These
views
and
the
composition
of
the
fund’s
portfolio
is
subject
to
change
at
any
time
based
on
market
and
other
conditions.
Not
FDIC-Insured
•
Not
Bank-Guaranteed
•
May
Lose
Value
Discussion
of
Fund
Performance
3
Fund
Performance
7
Understanding
Your
Fund’s
Expenses
8
Statement
of
Investments
9
Statement
of
Assets
and
Liabilities
12
Statement
of
Operations
13
Statement
of
Changes
in
Net
Assets
14
Financial
Highlights
15
Notes
to
Financial
Statements
16
Report
of
Independent
Registered
Public
Accounting
Firm
25
Important
Tax
Information
26
Information
About
the
Approval
of
the
Fund’s
Sub-Sub-Investment
Advisory
Agreement
27
Board
Members
Information
29
Officers
of
the
Trust
31
FOR
MORE
INFORMATION
Back
Cover
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
3
For
the
period
from
November
1,
2022,
through
October
31,
2023,
as
provided
by
Julianne
D.
McHugh
and
Nick
Pope,
Portfolio
Managers
employed
by
the
fund’s
sub-adviser,
Newton
Investment
Management
Limited.
Market
and
Fund
Performance
Overview
For
the
12-month
period
ending
October
31,
2023,
the
BNY
Mellon
Sustainable
US
Equity
ETF
(the
“fund”)
produced
a
net
asset
value
total
return
of
6.55%.
1
In
comparison,
the
fund’s
benchmark,
the
S&P
500
®
Index
(the
“Index”),
produced
a
total
return
of
10.13%
for
the
same
period.
2
Equities
gained
ground
during
the
reporting
period
as
inflationary
pressures
eased,
the
U.S.
Federal
Reserve
(the
“Fed”)
reduced
the
pace
of
interest-rate
hikes,
and
economic
growth
remained
positive.
The
fund
underperformed
the
Index
largely
due
to
disappointing
stock
selections
and
sector
allocations.
The
Fund’s
Investment
Approach
The
fund
seeks
long-term
capital
appreciation.
To
pursue
its
goal,
the
fund
normally
invests
at
least
80%
of
its
net
assets
(plus
the
amount
of
any
borrowings
for
investment
purposes)
in
equity
securities
of
U.S.
companies
that
demonstrate
attractive
investment
attributes
and
sustainable
business
practices.
The
fund
considers
a
U.S.
company
to
be
a
company
organized
or
with
its
principal
place
of
business
in,
or
that
has
a
majority
of
its
assets
or
business
in,
or
whose
securities
are
primarily
listed
or
traded
on
exchanges
in,
the
United
States.
The
fund’s
sub-adviser,
Newton
Investment
Management
Limited
(“NIM”),
an
affiliate
of
BNY
Mellon
ETF
Investment
Adviser,
LLC,
considers
a
company
to
be
engaged
in
“sustainable
business
practices”
if
the
company
engages
in
business
practices
that
are,
in
NIM's
view,
sustainable
in
an
economic
sense
(i.e.,
the
company’s
strategy,
operations
and
finances
are
stable
and
durable),
and
takes
appropriate
measures
to
manage
any
material
consequences
or
impact
of
its
policies
and
operations
in
relation
to
environmental,
social
and
governance
(ESG)
matters
(e.g.,
the
company’s
environmental
footprint,
labor
standards,
board
structure,
etc.).
Companies
engaged
in
sustainable
business
practices
also
may
include
companies
that
have
committed
explicitly
to
improving
their
environmental
and/or
social
impacts
that
will
lead
to
a
transformation
of
their
business
models.
Equities
Gain
Ground
as
Inflation
Eases
Large-cap
U.S.
equities
gained
ground
during
the
reporting
period
as
interest-rate
hikes
implemented
by
the
Fed
gained
traction
in
the
fight
against
inflation.
Inflation
decreased
from
more
than
7%
annually
in
November
2022
to
between
3%
and
4%
from
June
through
September
2023,
while
the
federal
funds
rate
rose
by
more
than
2%
to
a
range
of
5.25%–5.50%.
Counter
to
expectations,
despite
the
rise
in
interest
rates,
economic
growth
remained
relatively
strong,
bolstered
by
robust
consumer
spending.
As
a
result,
investor
expectations
turned
to
hopes
for
a
“soft
landing,”
in
which
the
Fed
would
bring
rates
under
control
without
triggering
a
serious
recession.
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
4
Growth-oriented
stocks
performed
particularly
well
in
this
environment,
with
market
strength
led
by
mega-cap
technology-related
names
leveraged
to
advances
in
artificial
intelligence
(“AI”).
Value-oriented
and
interest-rate-sensitive
stocks
underperformed,
with
the
utilities,
real
estate
and
health
care
sectors
lagging
the
Index
by
the
widest
margin.
Market
sentiment
shifted
during
the
last
three
months
of
the
period,
as
hawkish
comments
from
the
Fed
dashed
hopes
that
the
central
bank
might
soon
reverse
course
and
begin
to
reduce
interest
rates.
As
investors
absorbed
the
increasing
likelihood
that
rates
would
remain
higher
for
longer,
stocks
lost
some
of
their
earlier
gains.
Stock
Selections
and
Allocation
Detract
The
fund’s
performance
relative
to
the
Index
suffered
due
to
stock
selection
in
the
materials
and
information
technology
sectors
and,
to
a
lesser
extent,
communication
services
and
consumer
staples.
From
a
sector
perspective,
underweight
exposure
to
communication
services
and
overweight
exposure
to
utilities
detracted
as
well.
Among
notable
individual
detractors,
shares
in
Albemarle
Corp.,
the
world’s
largest
producer
of
lithium
for
electric
vehicle
(“EV”)
batteries,
declined
amid
slumping
lithium
prices.
Lack
of
exposure
to
surging
social
media
company
Meta
Platforms
detracted
as
well,
as
did
the
fund’s
position
in
food
ingredient
company
Darling
Ingredients,
Inc.
due
to
higher
energy
costs
in
Europe
and
operational
challenges.
Among
financials,
holdings
in
First
Republic
Bank
came
under
pressure
as
a
crisis
of
confidence
swept
the
regional
banking
sector
after
the
collapse
of
Silicon
Valley
Bank
and
closure
of
Signature
Bank
in
March
2023.
We
moved
swiftly
to
sell
the
fund’s
position
given
a
lack
of
clarity
as
to
whether
the
bank
would
remain
liquid.
Renewable
energy-related
holdings,
including
utility
NextEra
Energy,
Inc.
and
solar
battery
system
supplier
Enphase
Energy
,
proved
vulnerable
to
rising
interest
rates
and
inflation.
On
the
positive
side,
strong
stock
selection
bolstered
relative
returns
in
health
care
and
consumer
discretionary.
Lack
of
exposure
to
energy
and
real
estate
also
contributed
positively
against
a
backdrop
of
weak
economic
growth
in
China
and
rising
interest
rates.
Overweight
exposure
to
the
information
technology
sector
also
enhanced
the
fund’s
relative
performance,
although
disappointing
stock
selection
in
the
sector
more
than
offset
the
positive
impact.
At
the
stock
level,
leading
health
care
performers
included
pharmaceutical
companies
Eli
Lilly
&
Co.
and
Novo
Nordisk
.
Gains
in
Eli
Lilly
&
Co.
were
fueled
by
positive
news
regarding
the
company’s
treatments
for
obesity
and
Alzheimer’s,
and
strong
sales
of
diabetes
drug
Mounjaro.
Novo
Nordisk
also
saw
strong
sales
for
its
obesity
and
diabetes
drug,
Ozempic,
along
with
encouraging
news
from
a
study
that
found
significant
cardiovascular
benefits
for
patients
taking
the
medication.
Other
top
performers
included
technology
companies
benefiting
from
AI-driven
momentum,
including
enterprise
software
developer
Microsoft
Corp.,
which
made
progress
infusing
AI
across
its
platform
and
reported
strong
revenue
and
earnings.
Lack
of
exposure
to
EV
car
maker
Tesla
proved
beneficial
due
to
a
challenging
near-
term
demand
outlook.
5
Maintaining
Conviction
Despite
Macroeconomic
Challenges
If
prevailing
expectations
of
interest
rates
remaining
higher
for
longer
than
previously
expected
are
borne
out,
we
expect
the
associated
higher
cost
of
capital
to
negatively
affect
valuations
across
asset
classes.
However,
structural
demand
trends
remain
in
place
as
several
global
transitions
continue,
supported
in
some
cases
by
government
stimulus
and
support.
Against
this
backdrop,
we
continue
to
seek
out
businesses
with
attractive
sustainability
credentials,
durable
returns
and
quality
characteristics
leveraged
to
emerging
needs
and
demands.
As
of
October
31,
2023,
the
fund
holds
its
largest
overweight
position
relative
to
the
Index
in
information
technology.
We
see
strong
potential
given
the
sector’s
exposure
to
rapid
developments
in
AI
and
the
potential
for
our
“internet
of
things”
and
“smart
everything”
investment
themes.
The
fund
also
emphasizes
the
health
care
sector,
targeting
companies
offering
best-in-class
and
innovative
products,
services
and
solutions
to
serve
the
needs
and
tastes
of
an
aging
global
population.
Conversely,
the
fund
holds
relatively
underweight
exposure
to
the
consumer
discretionary
sector,
reflecting
our
caution
regarding
the
health
of
a
consumer
strained
by
higher
interest
rates.
The
fund
also
holds
zero
exposure
to
energy,
given
the
lack
of
business
characteristics
in
the
sector
consistent
with
the
portfolio’s
sustainable
mandate.
November
15,
2023
1
Total
return
includes
reinvestment
of
dividends
and
any
capital
gains
paid.
A
fund’s
net
asset
value
(NAV)
is
the
sum
of
all
its
assets
less
any
liabilities,
divided
by
the
number
of
shares
outstanding.
Exchange-Traded
Funds
(“ETFs”)
are
bought
and
sold
at
market
prices,
not
NAV,
therefore
an
investor’s
return
at
market
price
may
differ
from
NAV.
Past
performance
is
no
guarantee
of
future
results.
Share
price,
yield
and
investment
return
fluctuate
such
that
upon
redemption,
fund
shares
may
be
worth
more
or
less
than
their
original
cost.
2
Source:
Lipper
Inc.
—
The
S&P
500
®
Index
is
widely
regarded
as
the
best
single
gauge
of
large-cap
U.S.
equities.
The
Index
includes
500
leading
companies
and
captures
approximately
80%
coverage
of
available
market
capitalization.
Investors
cannot
invest
directly
in
any
index.
Please
note:
the
position
in
any
security
highlighted
with
italicized
typeface
was
sold
during
the
reporting
period.
ETFs
trade
like
stocks,
are
subject
to
investment
risk,
including
possible
loss
of
principal.
ETF
shares
are
listed
on
an
exchange,
and
shares
are
generally
purchased
and
sold
in
the
secondary
market
at
market
price.
At
times,
the
market
price
may
be
at
a
premium
or
discount
to
the
ETF’s
per
share
NAV.
In
addition,
ETFs
are
subject
to
the
risk
that
an
active
trading
market
for
an
ETF’s
shares
may
not
develop
or
be
maintained.
Buying
or
selling
ETF
shares
on
an
exchange
may
require
payment
of
brokerage
commissions.
“Standard
&
Poor’s
®
,”
“S&P
®
,”
“Standard
&
Poor’s
®
500,”
and
“S&P
500
®
”
are
registered
trademarks
of
Standard
&
Poor’s
Financial
Services
LLC
and
have
been
licensed
for
use
on
behalf
of
the
fund.
The
fund
is
not
sponsored,
managed,
DISCUSSION
OF
FUND
PERFORMANCE
(Unaudited)
(continued)
6
advised,
sold
or
promoted
by
Standard
&
Poor’s
and
its
affiliates,
and
Standard
&
Poor’s
and
its
affiliates
make
no
representation
regarding
the
advisability
of
investing
in
the
fund.
The
fund
may,
but
is
not
required
to,
use
derivative
instruments.
A
small
investment
in
derivatives
could
have
a
potentially
large
impact
on
the
fund’s
performance.
The
use
of
derivatives
involves
risks
different
from,
or
possibly
greater
than,
the
risks
associated
with
investing
directly
in
the
underlying
assets.
Equities
are
subject
generally
to
market,
market
sector,
market
liquidity,
issuer
and
investment
style
risks,
among
other
factors,
to
varying
degrees,
all
of
which
are
more
fully
described
in
the
fund’s
prospectus.
The
fund
is
non-diversified,
which
means
that
the
fund
may
invest
a
relatively
high
percentage
of
its
assets
in
a
limited
number
of
issuers.
Therefore,
the
fund’s
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
Environmental,
social
and
governance
(ESG)
managers
may
take
into
consideration
factors
beyond
traditional
financial
information
to
select
securities,
which
could
result
in
relative
investment
performance
deviating
from
other
strategies
or
broad
market
benchmarks,
depending
on
whether
such
sectors
or
investments
are
in
or
out
of
favor
in
the
market.
Further,
ESG
strategies
may
rely
on
certain
values-based
criteria
to
eliminate
exposures
found
in
similar
strategies
or
broad
market
benchmarks,
which
could
also
result
in
relative
investment
performance
deviating.
FUND
PERFORMANCE
(Unaudited)
7
Comparison
of
change
in
value
of
a
$10,000
investment
in
BNY
Mellon
Sustainable
US
Equity
ETF
with
a
hypothetical
investment
of
$10,000
in
the
S&P
500
®
Index
(the
“Index”).
†
Source:
Lipper
Inc.
††
The
inception
date
is
the
first
date
the
fund
was
available
on
NYSE
Arca,
Inc.
Past
performance
is
not
predictive
of
future
performance.
The
above
graph
compares
a
hypothetical
$10,000
investment
made
in
BNY
Mellon
Sustainable
US
Equity
ETF
on
12/14/21
to
a
hypothetical
investment
of
$10,000
made
in
the
Index
on
that
date
using
closing
market
price
return.
All
dividends
and
capital
gain
distributions
are
reinvested.
The
fund’s
performance
shown
in
the
line
graph
above
takes
into
account
all
applicable
fees
and
expenses.
The
Index
(Europe,
Australasia,
Far
East)
is
a
free
float-adjusted,
market
capitalization-weighted
index
that
is
designed
to
measure
the
equity
market
performance
of
developed
markets,
excluding
the
U.S.
and
Canada.
It
reflects
reinvestment
of
net
dividends
and,
where
applicable,
capital
gain
distributions.
Investors
cannot
invest
directly
in
any
index.
Further
information
relating
to
fund
performance,
including
expense
reimbursements,
if
applicable,
is
contained
in
the
Financial
Highlight
section
of
the
prospectus
and
elsewhere
in
this
report.
The
performance
data
quoted
represents
past
performance,
which
is
no
guarantee
of
future
results.
Share
price
and
investment
return
fluctuate
and
an
investor’s
shares
may
be
worth
more
or
less
than
original
cost
upon
redemption.
Current
performance
may
be
lower
or
higher
than
the
performance
quoted.
Go
to
www.
im.bnymellon.com
for
the
fund’s
most
recent
month-end
returns.
The
fund’s
performance
shown
in
the
graph
and
table
does
not
reflect
the
deduction
of
taxes
that
a
shareholder
would
pay
on
fund
distributions
or
the
redemption
of
fund
shares.
Average
Annual
Total
Returns
as
of
October
31,
2023
Inception
Date
††
1
Year
From
Inception
BNY
Mellon
Sustainable
US
Equity
ETF
Net
Asset
Value
Return
12/14/21
6.55%
(14.68)%
Market
Price
Return
12/14/21
6.56%
(14.68)%
S&P
500
®
Index
12/14/21
10.13%
(5.30)%
UNDERSTANDING
YOUR
FUND’S
EXPENSES
(Unaudited)
8
As
a
shareholder
of
the
fund,
you
pay
ongoing
expenses,
such
as
management
fees
and
other
expenses.
Using
the
information
below,
you
can
estimate
how
these
expenses
affect
your
investment
and
compare
them
with
the
expenses
of
other
funds.
For
more
information,
see
your
fund’s
prospectus
or
talk
to
your
financial
adviser.
Actual
Expenses
The
table
below
shows
the
expenses
you
would
have
paid
on
a
$1,000
investment
in
the
fund
from
May
1,
2023
to
October
31,
2023.
The
information
under
each
column
in
the
table
below
entitled
“Actual”
provides
information
about
on
how
much
a
$1,000
investment
would
be
worth
at
the
close
of
the
period,
assuming
net
asset
value
total
returns
and
actual
expenses.
You
may
use
the
information
in
these
columns,
together
with
the
amount
you
invested,
to
estimate
the
expenses
that
you
paid
over
the
period.
Simply
divide
your
account
value
by
$1,000
(for
example,
an
$8,600
account
value
divided
by
$1,000
=
8.6),
then
multiply
the
result
by
the
number
for
the
fund
under
the
heading
entitled
“Expenses
paid
for
the
period”
to
estimate
the
expenses
you
paid
on
your
account
during
this
period.
Hypothetical
Example
For
Comparison
Purposes
The
Securities
and
Exchange
Commission
(“SEC”)
has
established
guidelines
to
help
investors
assess
fund
expenses.
The
information
under
each
column
in
the
table
entitled
“Hypothetical”
provides
information
about
hypothetical
account
values
and
hypothetical
expenses
based
on
the
fund’s
actual
expense
ratio
and
assuming
a
hypothetical
5%
annualized
return,
which
is
not
the
fund’s
actual
return.
The
hypothetical
account
values
and
expenses
may
not
be
used
to
estimate
the
actual
ending
account
balance
or
expenses
you
paid
for
the
period.
You
may
use
this
information
to
compare
the
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
To
do
so,
compare
this
5%
hypothetical
example
with
the
5%
hypothetical
examples
that
appear
in
the
shareholder
reports
of
the
other
funds.
Please
note
that
the
expenses
shown
in
the
table
are
meant
to
highlight
your
ongoing
costs
only
and
do
not
reflect
any
transactional
costs,
such
as
brokerage
commissions
paid
on
purchases
and
sales
of
fund
shares.
Therefore,
the
ending
account
values
and
expenses
paid
for
the
period
in
the
table
are
useful
in
comparing
ongoing
expenses
(but
not
transaction
expenses
or
total
cost)
of
investing
in
the
fund
with
those
of
other
funds.
In
addition,
if
these
transactional
costs
were
included,
your
costs
would
have
been
higher.
For
the
six
months
ended
October
31,
2023
(a)
Expenses
are
calculated
using
the
annualized
expense
ratio,
which
represents
the
ongoing
expenses
as
a
percentage
of
net
assets
for
the
six-month
period
ended
October
31,
2023.
Expenses
are
calculated
by
multiplying
the
fund’s
annualized
expense
ratio
by
the
average
account
value
for
the
period,
then
multiplying
the
result
by
184/365
(to
reflect
the
one-half
period).
Beginning
account
value
($)
Ending
account
value($)
Expense
paid
for
the
period
($)
Annualized
expense
ratios
for
the
period
(%)
Actual
Hypothetical
Actual
Hypothetical
Actual
(a)
Hypothetical
(a)
1,000.00
1,000.00
1,006.10
1,022.68
2.53
2.55
0.50
STATEMENT
OF
INVESTMENTS
October
31,
2023
9
Description
Shares
Value
($)
Common
Stocks
–
97.7%
Banks
–
3.1%
JPMorgan
Chase
&
Co.
1,860
258,652
Capital
Goods
–
4.1%
Ingersoll
Rand,
Inc.
2,940
178,399
Trane
Technologies
PLC
866
164,809
343,208
Commercial
&
Professional
Services
–
2.5%
Veralto
Corp.
(a)
866
59,754
Waste
Management,
Inc.
934
153,484
213,238
Consumer
Discretionary
Distribution
&
Retail
–
4.7%
Amazon.com,
Inc.
(a)
2,967
394,878
Consumer
Durables
&
Apparel
–
2.1%
Lululemon
Athletica,
Inc.
(a)
455
179,033
Consumer
Staples
Distribution
&
Retail
–
3.1%
Costco
Wholesale
Corp.
473
261,304
Financial
Services
–
4.7%
Goldman
Sachs
Group,
Inc.
(The)
479
145,429
Mastercard,
Inc.,
Class
A
674
253,660
399,089
Food,
Beverage
&
Tobacco
–
4.0%
Darling
Ingredients,
Inc.
(a)
2,260
100,095
PepsiCo,
Inc.
1,438
234,797
334,892
Health
Care
Equipment
&
Services
–
6.1%
Boston
Scientific
Corp.
(a)
4,776
244,484
DexCom,
Inc.
(a)
1,080
95,936
UnitedHealth
Group,
Inc.
335
179,413
519,833
Insurance
–
5.0%
Progressive
Corp.
(The)
1,493
236,028
RenaissanceRe
Holdings
Ltd.
852
187,091
423,119
Materials
–
3.6%
Albemarle
Corp.
700
88,746
CF
Industries
Holdings,
Inc.
1,393
111,133
Ecolab,
Inc.
643
107,857
307,736
Media
&
Entertainment
–
5.1%
Alphabet,
Inc.,
Class
A
(a)
3,458
429,069
STATEMENT
OF
INVESTMENTS
(continued)
10
Description
Shares
Value
($)
Common
Stocks
–
97.7%
(continued)
Pharmaceuticals,
Biotechnology
&
Life
Sciences
–
10.0%
AbbVie,
Inc.
1,518
214,311
BioMarin
Pharmaceutical,
Inc.
(a)
1,011
82,346
Danaher
Corp.
921
176,850
Eli
Lilly
&
Co.
450
249,269
Zoetis,
Inc.
806
126,542
849,318
Semiconductors
&
Semiconductor
Equipment
–
6.6%
Applied
Materials,
Inc.
1,066
141,085
NVIDIA
Corp.
787
320,939
Texas
Instruments,
Inc.
671
95,289
557,313
Software
&
Services
–
19.0%
Accenture
PLC,
Class
A
760
225,789
Akamai
Technologies,
Inc.
(a)
1,325
136,912
ANSYS,
Inc.
(a)
409
113,808
Intuit,
Inc.
449
222,233
Microsoft
Corp.
2,138
722,879
Roper
Technologies,
Inc.
386
188,588
1,610,209
Technology
Hardware
&
Equipment
–
9.0%
Apple,
Inc.
3,667
626,213
TE
Connectivity
Ltd.
1,175
138,474
764,687
Transportation
–
1.6%
Norfolk
Southern
Corp.
718
136,987
Utilities
–
3.4%
CMS
Energy
Corp.
2,548
138,458
NextEra
Energy,
Inc.
2,520
146,916
285,374
Total
Common
Stocks
(cost
$8,733,148)
8,267,939
Investment
Companies
–
2.2%
Registered
Investment
Companies
–
2.2%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares,
5.32%
(b)(c)
(cost
$183,887)
183,887
183,887
Total
Investments
(cost
$8,917,035)
99.9%
8,451,826
Cash
and
Receivables
(Net)
0.1%
5,972
Net
Assets
100.0%
8,457,798
(a)
Non-income
producing
security.
(b)
Investment
in
affiliated
issuer.
The
investment
objective
of
this
investment
company
is
publicly
available
and
can
be
found
within
the
investment
company’s
prospectus.
(c)
The
rate
shown
is
the
1-day
yield
as
of
October
31,
2023.
11
See
Notes
to
Financial
Statements
Portfolio
Summary
(Unaudited)
†
Value
(%)
Information
Technology
34.6
Health
Care
16.1
Financials
12.8
Industrials
8.2
Consumer
Staples
7.1
Consumer
Discretionary
6.8
Communication
Services
5.1
Materials
3.6
Utilities
3.4
Registered
Investment
Companies
2.2
99.9
†
Based
on
net
assets.
Holdings
and
transactions
in
these
affiliated
companies
during
the
period
ended
October
31,
2023
are
as
follows:
Description
Value
($)
10/31/22
Purchases
($)
1
Sales
($)
Value
($)
10/31/23
Dividends/
Distributions
($)
Investment
Companies
–
2.2%
Dreyfus
Institutional
Preferred
Government
Money
Market
Fund,
Institutional
Shares
212,002
918,856
(946,971)
183,887
11,255
Total
–
2.2%
212,002
918,856
(946,971)
183,887
11,255
1
Includes
reinvested
dividends/distributions.
STATEMENT
OF
ASSETS
AND
LIABILITIES
October
31,
2023
12
See
Notes
to
Financial
Statements
Cost
Value
Assets
($):
Investments
in
securities—See
Statement
of
Investments:
–
Unaffiliated
issuers
8,733,148
8,267,939‌
Affiliated
issuers
183,887
183,887‌
Receivable
for
investment
securities
sold
41,683‌
Dividends
receivable
5,419‌
Tax
reclaim
receivable—Note
2(b)
245‌
8,499,173‌
Liabilities
($):
Due
to
BNY
Mellon
ETF
Investment
Adviser,
LLC—
Note
3(b)
3,638‌
Payable
for
investment
securities
purchased
37,737‌
41,375‌
Net
Assets
($)
8,457,798‌
Composition
of
Net
Assets
($):
Paid-in
capital
10,000,050‌
Total
distributable
earnings
(loss)
(1,542,252‌)
Net
Assets
($)
8,457,798‌
Shares
outstanding
no
par
value
(unlimited
shares
authorized):
200,001‌
Net
asset
value
per
share
42.29‌
Market
price
per
share
42.29‌
STATEMENT
OF
OPERATIONS
Year
Ended
October
31,
2023
13
See
Notes
to
Financial
Statements
Investment
Income
($):
Income:
Cash
dividends:
Unaffiliated
issuers
101,416‌
Affiliated
issuers
11,255‌
Total
Income
112,671‌
Expenses:
Management
fee—Note
3(a)
50,739‌
Total
Expenses
50,739‌
Less—reduction
in
fees
due
pursuant
to
undertaking—Note
3(a)
(5,797‌)
Net
Expenses
44,942‌
Net
Investment
Income
67,729‌
Realized
and
Unrealized
Gain
(Loss)
on
Investments—Note
4
($):
Net
realized
gain
(loss)
on
investments
(804,192‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
1,254,221‌
Net
Realized
and
Unrealized
Gain
(Loss)
on
Investments
450,029‌
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
517,758‌
STATEMENT
OF
CHANGES
IN
NET
ASSETS
14
See
Notes
to
Financial
Statements
Year
Ended
October
31,
2023
For
the
Period
from
December
15,
2021
(a)
to
October
31,
2022
Operations
($):
Net
investment
income
67,729‌
55,436‌
Net
realized
gain
(loss)
on
investments
(804,192‌)
(328,618‌)
Net
change
in
unrealized
appreciation
(depreciation)
on
investments
1,254,221‌
(1,719,430‌)
Net
Increase
(Decrease)
in
Net
Assets
Resulting
from
Operations
517,758‌
(1,992,612‌)
Distributions
($):
Distributions
to
shareholders
(67,044‌)
(354‌)
Beneficial
Interest
Transactions
($):
Proceeds
from
shares
sold
—‌
10,000,050‌
Increase
(Decrease)
in
Net
Assets
from
Beneficial
Interest
Transactions
—‌
10,000,050‌
Total
Increase
(Decrease)
in
Net
Assets
450,714‌
8,007,084‌
Net
Assets
($):
Beginning
of
Period
8,007,084‌
—‌
End
of
Period
8,457,798‌
8,007,084‌
Changes
in
Shares
Outstanding:
Shares
sold
—‌
200,001‌
Net
Increase
(Decrease)
in
Shares
Outstanding
—‌
200,001‌
(a)
Commencement
of
operations.
FINANCIAL
HIGHLIGHTS
15
The
following
table
describes
the
performance
for
the
fiscal
periods
indicated
and
these
figures
have
been
derived
from
the
fund’s
financial
statements.
See
Notes
to
Financial
Statements
Year
Ended
October
31,
2023
For
the
Period
from
December
15,
2021
(a)
to
October
31,
2022
Per
Share
Data
($):
Net
asset
value,
beginning
of
period
40.04‌
50.00‌
Investment
Operations:
Net
investment
income
(b)
0.34‌
0.28‌
Net
realized
and
unrealized
gain
(loss)
on
investments
2.25‌
(10.24‌)
Total
from
Investment
Operations
2.59‌
(9.96‌)
Distributions:
–
–
Dividends
from
net
investment
income
(0.34‌)
(0.00‌)
(c)
Net
asset
value,
end
of
period
42.29‌
40.04‌
Market
price,
end
of
period
42.29‌
40.03‌
Net
Asset
Value
Total
Return
(%)
(d)
6.55‌
(19.93‌)
(e)
Market
Price
Total
Return
(%)
(d)
6.56‌
(19.94‌)
(e)
Ratios/Supplemental
Data
(%):
Ratio
of
total
expenses
to
average
net
assets
0.60‌
0.60‌
(f)
Ratio
of
net
expenses
to
average
net
assets
0.53‌
0.60‌
(f)
Ratio
of
net
investment
income
to
average
net
assets
0.80‌
0.72‌
(f)
Portfolio
Turnover
Rate
(g)
36.66‌
28.58‌
Net
Assets,
end
of
period
($
x
1,000)
8,458‌
8,007‌
(a)
Commencement
of
operations.
(b)
Based
on
average
shares
outstanding.
(c)
Amount
represents
less
than
$(0.01)
per
share.
(d)
Net
asset
value
total
return
is
calculated
assuming
an
initial
investment
made
at
the
net
asset
value
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
net
asset
value
during
the
period,
and
redemption
at
net
asset
value
on
the
last
day
of
the
period.
Net
asset
value
total
return
includes
adjustments
in
accordance
with
accounting
principles
generally
accepted
in
the
United
States
of
America
and
as
such,
the
net
asset
value
for
financial
reporting
purposes
and
the
returns
based
upon
those
net
asset
values
may
differ
from
the
net
asset
value
and
returns
for
shareholder
transactions.
Market
price
total
return
is
calculated
assuming
an
initial
investment
made
at
the
market
price
at
the
beginning
of
the
period,
reinvestment
of
all
dividends
and
distributions
at
market
price
during
the
period,
and
sale
at
the
market
price
on
the
last
day
of
the
period.
Total
investment
returns
calculated
for
a
period
of
less
than
one
year
are
not
annualized.
(e)
The
net
asset
value
total
return
and
the
market
price
total
return
is
calculated
from
fund
inception.
The
inception
date
is
the
first
date
the
fund
was
available
on
NYSE
Arca,
Inc.
(f)
Annualized.
(g)
Portfolio
turnover
rate
is
not
annualized
for
periods
less
than
one
year,
if
applicable,
and
does
not
include
securities
received
or
delivered
from
processing
creations
or
redemptions.
NOTES
TO
FINANCIAL
STATEMENTS
16
NOTE
1—Organization:
BNY
Mellon
Sustainable
US
Equity
ETF (the “fund”) is a
separate
non-diversified series
of
BNY
Mellon
ETF
Trust
(the
“Trust”),
which is
registered as
a
Massachusetts
business
trust
under
the
Investment
Company
Act
of
1940,
as
amended
(the
“Act”),
as
an
open-ended
management
investment
company.
The
Trust
operates
as
a
series
company
currently
consisting
of
sixteen
series,
including
the
fund.
The
investment
objective
of
the
fund
is
to
seek
long-term
capital
appreciation.
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”),
a
wholly-owned
subsidiary
of
The
Bank
of
New
York
Mellon
Corporation
(“BNY
Mellon”),
serves
as
the
fund’s
investment
adviser. Newton
Investment
Management
Limited (the
“Sub-Adviser”
or
“NIM”),
an
indirect wholly-owned
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
the
fund’s
sub-adviser.
The
Bank
of
New
York
Mellon,
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser,
serves
as
administrator,
custodian
and
transfer
agent
with
the
Trust.
BNY
Mellon
Securities
Corporation
(the
“Distributor”),
a wholly-owned
subsidiary
of
the
Adviser,
is
the
distributor
of
the
fund’s
shares.
Effective
May
31,
2023,
the
Sub-Adviser
entered
into
a
sub-sub-investment
advisory
agreement
with
its
affiliate,
Newton
Investment
Management
North
America,
LLC
(“NIMNA”),
to
enable
NIMNA
to
provide
certain
advisory
services
to
the
Sub-
Adviser
for
the
benefit
of
the
fund,
including,
but
not
limited
to,
portfolio
management
services.
NIMNA
is
subject
to
the
supervision
of
the
Sub-Adviser
and
the
Adviser.
NIMNA
is
also
an
affiliate
of
the
Adviser.
NIMNA’s
principal
office
is
located
at
BNY
Mellon
Center,
201
Washington
Street,
Boston,
MA
02108.
NIMNA
is
an
indirect
subsidiary
of
BNY
Mellon.
The
shares
of
the
fund
are
referred
to
herein
as
“Shares”
or
“Fund’s
Shares.”
The
Fund’s
Shares
are
listed
and
traded
on
NYSE
Arca,
Inc.
The
market
price
of
each
Share
may
differ
to
some
degree
from
the
fund’s
net
asset
value
(“NAV”).
Unlike
conventional
mutual
funds,
the
fund
issues
and
redeems
Shares
on
a
continuous
basis,
at
NAV,
only
in
a
large
specified
number
of
Shares,
each
called
a
“Creation
Unit.”
Creation
Units
are
issued
and
redeemed
principally
in
exchange
for
the
deposit
or
delivery
of
a
basket
of
securities.
Except
when
aggregated
in
Creation
Units
by
Authorized
Participants,
the
Shares
are
not
individually
redeemable
securities
of
the
fund.
Individual
Fund
Shares
may
only
be
purchased
and
sold
on
the
NYSE
Arca,
Inc.,
other
national
securities
exchanges,
electronic
crossing
networks
and
other
alternative
trading
systems
through
your
broker-dealer
at
market
prices.
Because
Fund
Shares
trade
at
market
prices
rather
than
at
NAV,
Fund
Shares
may
trade
at
a
price
greater
than
NAV
(premium)
or
less
than
NAV
(discount).
When
buying
or
selling
Shares
in
the
secondary
market,
you
may
incur
costs
attributable
to
the
difference
between
the
highest
price
a
buyer
is
willing
to
pay
to
purchase
Shares
of
the
fund
(bid)
and
the
lowest
price
a
seller
is
willing
to
accept
for
Shares
of
the
fund
(ask). 
17
NOTE
2—Significant
Accounting
Policies: 
The
Financial
Accounting
Standards
Board
(“FASB”)
Accounting
Standards
Codification
(“ASC”)
is
the
exclusive
reference
of
authoritative
U.S.
generally
accepted
accounting
principles
(“GAAP”)
recognized
by
the
FASB
to
be
applied
by
nongovernmental
entities.
Rules
and
interpretive
releases
of
the
SEC
under
authority
of
federal
laws
are
also
sources
of
authoritative
GAAP
for
SEC
registrants. The
fund
is an
investment
company
and
applies
the
accounting
and
reporting
guidance
of
the
FASB
ASC
Topic
946
Financial
Services-Investment
Companies. The
fund’s
financial
statements
are
prepared
in
accordance
with
GAAP,
which
may
require
the
use
of
management
estimates
and
assumptions.
Actual
results
could
differ
from
those
estimates.  
The
Trust
accounts
separately
for
the
assets,
liabilities
and
operations
of
each
series.
Expenses
directly
attributable
to
each
series
are
charged
to
that
series’
operations;
expenses
which
are
applicable
to
all
series
are
allocated
among
them
on
a
pro
rata
basis.
The
Trust
enters
into
contracts
that
contain
a
variety
of
indemnifications.
The
fund’s
maximum
exposure
under
these
arrangements
is
unknown.
The
fund
does
not
anticipate
recognizing
any
loss
related
to
these
arrangements. 
(a)
Portfolio
valuation:
The
fair
value
of
a
financial
instrument
is
the
amount
that
would
be
received
to
sell
an
asset
or
paid
to
transfer
a
liability
in
an
orderly
transaction
between
market
participants
at
the
measurement
date
(i.e.,
the
exit
price).
GAAP
establishes
a
fair
value
hierarchy
that
prioritizes
the
inputs
of
valuation
techniques
used
to
measure
fair
value.
This
hierarchy
gives
the
highest
priority
to
unadjusted
quoted
prices
in
active
markets
for
identical
assets
or
liabilities
(Level
1
measurements)
and
the
lowest
priority
to
unobservable
inputs
(Level
3
measurements).
Additionally,
GAAP
provides
guidance
on
determining
whether
the
volume
and
activity
in
a
market
has
decreased
significantly
and
whether
such
a
decrease
in
activity
results
in
transactions
that
are
not
orderly.
GAAP
requires
enhanced
disclosures
around
valuation
inputs
and
techniques
used
during
annual
and
interim
periods.
Various
inputs
are
used
in
determining
the
value
of
the
fund’s
investments
relating
to
fair
value
measurements.
These
inputs
are
summarized
in
the
three
broad
levels
listed
below:
Level
1
—
unadjusted
quoted
prices
in
active
markets
for
identical
investments.
Level
2
—
other
significant
observable
inputs
(including
quoted
prices
for
similar 
investments,
interest
rates,
prepayment
speeds,
credit
risk,
etc.).
Level
3
—
significant
unobservable
inputs
(including
the
fund’s
own
assumptions
in
determining
the
fair
value
of
investments).
The
inputs
or
methodology
used
for
valuing
securities
are
not
necessarily
an
indication
of
the
risk
associated
with
investing
in
those
securities.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
18
Changes
in
valuation
techniques
may
result
in
transfers
in
or
out
of
an
assigned
level
within
the
disclosure
hierarchy.
Valuation
techniques
used
to
value
the
fund’s
investments
are
as
follows:
The
Trust’s Board
of
Trustees
(the
“Board”)
has
designated
the
Adviser
as
the
fund’s
valuation
designee
to
make
all
fair
value
determinations
with
respect
to
the
fund’s
portfolio
of
investments,
subject
to
the
Board’s
oversight
and
pursuant
to
Rule
2a-5
under
the
Act.
Investments
in
equity
securities,
including
ETFs
(but
not
including
investments
in
other
open-end
registered
investment
companies),
generally
are
valued
at
the
last
sales
price
on
the
day
of
valuation
on
the
securities
exchange
or
national
securities
market
on
which
such
securities
primarily
are
traded.
Securities
listed
on
the
National
Association
of
Securities
Dealers
Automated
Quotation
System
(“NASDAQ”)
for
which
market
quotations
are
available
will
be
valued
at
the
official
closing
price.
If
there
are
no
transactions
in
a
security,
or
no
official
closing
prices
for
a
NASDAQ
market-listed
security
on
that
day,
the
security
will
be
valued
at
the
average
of
the
most
recent
bid
and
asked
prices.
Bid
price
is
used
when
no
asked
price
is
available.
Open
short
positions
for
which
there
is
no
sale
price
on
a
given
day
are
valued
at
the
lowest
asked
price.
Registered
investment
companies
that
are
not
traded
on
an
exchange
are
valued
at
their
net
asset
value.
All
of
the
preceding
securities
are
generally
categorized
within
Level
1
of
the
fair
value
hierarchy. 
When
market
quotations
or
official
closing
prices
are
not
readily
available,
or
are
determined
not
to
reflect
fair
value
accurately,
they are
valued
at
fair
value
as
determined
in
good
faith
based
on
procedures
approved
by
the
Board.
Fair
value
of
investments
may
be
determined
by
valuation
designee
using
such
information
as
it
deems
appropriate
under
the
circumstances.
Certain
factors
may
be
considered
when
fair
valuing
investments
such
as:
fundamental
analytical
data,
the
nature
and
duration
of
restrictions
on
disposition,
an
evaluation
of
the
forces
that
influence
the
market
in
which
the
securities
are
purchased
and
sold,
and
public
trading
in
similar
securities
of
the
issuer
or
comparable
issuers.
These
securities
are
either
categorized
within
Level
2
or
3
of
the
fair
value
hierarchy
depending
on
the
relevant
inputs
used.
For
securities
where
observable
inputs
are
limited,
assumptions
about
market
activity
and
risk
are
used
and
are
generally
categorized
within
Level
3
of
the
fair
value
hierarchy.
The
table
below
summarizes
the
inputs
used
as
of October
31,
2023
in
valuing
the
fund’s
investments:
19
Fair
Value
Measurements
(b) Securities
transactions
and
investment
income:
Securities
transactions
are
recorded
on
a
trade
date
basis.
Realized
gains
and
losses
from
securities
transactions
are
recorded
on
the
identified
cost
basis.
Dividend
income
is
recognized
on
the
ex-
dividend
date
and
interest
income,
including,
where
applicable,
accretion
of
discount
and
amortization
of
premium
on
investments,
is
recognized
on
the
accrual
basis.
(c)
Affiliated
issuers:
Investments
in
other
investment
companies
advised
by
the
Adviser
or
its
affiliates are
defined
as
“affiliated”
under
the
Act. 
(d)
Market
Risk:
The
value
of
the
securities
in
which
the
fund
invests
may
be
affected
by
political,
regulatory,
economic
and
social
developments,
and
developments
that
impact
specific
economic
sectors,
industries
or
segments
of
the
market.
In
addition,
turbulence
in
financial
markets
and
reduced
liquidity
in
equity,
credit
and/
or
fixed
income
markets
may
negatively
affect
many
issuers,
which
could
adversely
affect
the
fund.
Global
economies
and
financial
markets
are
becoming
increasingly
interconnected,
and
conditions
and
events
in
one
country,
region
or
financial
market
may
adversely
impact
issuers
in
a
different
country,
region
or
financial
market.
These
risks
may
be
magnified
if
certain
events
or
developments
adversely
interrupt
the
global
supply
chain;
in
these
and
other
circumstances,
such
risks
might
affect
companies
world-wide.
Sustainable
Investment
Approach
Risk:
The
fund’s
sustainable
investment
approach
may
cause
it
to
make
different
investments
than
funds
that
invest
principally
in
equity
securities
of
U.S.
companies
that
do
not
incorporate
sustainable
investment
criteria
when
selecting
investments.
Under
certain
economic
conditions,
this
could
cause
the
fund
to
underperform
funds
that
do
not
incorporate
similar
criteria.
For
example,
the
incorporation
of
sustainable
investment
criteria
may
result
in
the
fund
forgoing
opportunities
to
buy
certain
securities
when
it
might
otherwise
be
advantageous
to
do
so
or
selling
securities
when
it
might
otherwise
be
disadvantageous
for
the
fund
to
do
so.
The
incorporation
of
sustainable
investment
criteria
may
also
affect
the
fund’s
exposure
to
certain
sectors
and/or
types
of
investments,
and
may
adversely
impact
the
fund’s
performance
depending
on
whether
such
sectors
or
investments
are
in
or
out
of
favor
in
the
market.
NIM’s
security
selection
process
incorporates
ESG
data
provided
by
third
parties,
which
may
be
limited
for
certain
companies
and/or
only
Level
1
-
Unadjusted
Quoted
Prices
Level
2
-
Other
Significant
Observable
Inputs
Level
3
-
Significant
Unobservable
Inputs
Total
Assets
($)
Investments
In
Securities:
†
Common
Stocks
8,267,939
—
—
8,267,939
Investment
Companies
183,887
—
—
183,887
†
See
Statement
of
Investments
for
additional
detailed
categorizations,
if
any.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
20
take
into
account
one
or
a
few
ESG
related
components.
In
addition,
ESG
data
may
include
qualitative
and/or
quantitative
measures,
and
consideration
of
this
data
may
be
subjective.
Different
methodologies
may
be
used
by
the
various
data
sources
that
provide
ESG
data.
ESG
data
from
third
parties
used
by
NIM
as
part
of
its
sustainable
investment
process
often
lacks
standardization,
consistency
and
transparency,
and
for
certain
companies
such
data
may
not
be
available,
complete
or
accurate.
NIM’s
evaluation
of
ESG
factors
relevant
to
a
particular
company
may
be
adversely
affected
in
such
instances.
As
a
result,
the
fund’s
investments
may
differ
from,
and
potentially
underperform,
funds
that
incorporate
ESG
data
from
other
sources
or
utilize
other
methodologies.
Non-Diversification
Risk:
The
fund
is
non-diversified,
which
means
that
the
fund
may
invest
a
relatively
high
percentage
of
its
assets
in
a
limited
number
of
issuers.
Therefore,
the
fund’s
performance
may
be
more
vulnerable
to
changes
in
the
market
value
of
a
single
issuer
or
group
of
issuers
and
more
susceptible
to
risks
associated
with
a
single
economic,
political
or
regulatory
occurrence
than
a
diversified
fund.
Authorized
Participants,
Market
Makers
and
Liquidity
Providers
Risk:
The
fund
has
a
limited
number
of
financial
institutions
that
may
act
as
Authorized
Participants,
which
are
responsible
for
the
creation
and
redemption
activity
for
the
fund.
In
addition,
there
may
be
a
limited
number
of
market
makers
and/or
liquidity
providers
in
the
marketplace.
To
the
extent
either
of
the
following
events
occur,
fund
shares
may
trade
at
a
material
discount
to
net
asset
value
and
possibly
face
delisting:
(i)
Authorized
Participants
exit
the
business
or
otherwise
become
unable
to
process
creation
and/or
redemption
orders
and
no
other
Authorized
Participants
step
forward
to
perform
these
services,
or
(ii)
market
makers
and/or
liquidity
providers
exit
the
business
or
significantly
reduce
their
business
activities
and
no
other
entities
step
forward
to
perform
their
functions.
(e)
Dividends
and
distributions
to
shareholders:
Dividends
and
distributions
are
recorded
on
the
ex-dividend
date.
Dividends
from
net
investment
income
and
dividends
from
net
realized
capital
gains,
if
any,
are
normally
declared
and
paid
annually,
but
the
fund
may
make
distributions
on
a
more
frequent
basis
to
comply
with
the
distribution
requirements
of
the
Internal
Revenue
Code
of
1986,
as
amended
(the
“Code”).
To
the
extent
that
net
realized
capital
gains
can
be
offset
by
capital
loss
carryovers
of
a
fund,
it
is
the
policy
of
the
fund
not
to
distribute
such
gains.
Income
and
capital
gain
distributions
are
determined
in
accordance
with
income
tax
regulations,
which
may
differ
from
GAAP.
(f)
Federal
income
taxes:
It
is
the
policy
of
the
fund
to
continue
to
qualify
as
a
regulated
investment
company,
if
such
qualification
is
in
the
best
interests
of
its
shareholders,
by
complying
with
the
applicable
provisions
of
the
Code,
and
to
make
distributions
of
taxable
income
and
net
realized
capital
gain
sufficient
to
relieve
it
from
substantially
all
federal
income
and
excise
taxes.
21
As
of
and
during
the period
ended October
31,
2023,
the
fund
did
not
have
any
liabilities
for
any
uncertain
tax
positions.
The
fund
recognizes
interest
and
penalties,
if
any,
related
to
uncertain
tax
positions
as
income
tax
expense
in
the
Statement
of
Operations.
During
the period
ended October
31,
2023,
the
fund
did
not
incur
any
interest
or
penalties.
Each
tax
year
in
the
two-year
period
ended October
31,
2023
remains
subject
to
examination
by
the
Internal
Revenue
Service
and
state
taxing
authorities. 
At October
31,
2023,
the
components
of
accumulated
earnings
on
a
tax
basis
were
as
follows:
undistributed
ordinary
income
$50,149,
accumulated
capital
losses
$1,126,929, and
unrealized depreciation
$465,472.
The
fund is
permitted
to
carry
forward
capital
losses
for
an
unlimited
period.
Furthermore,
capital
loss
carryovers
retain
their
character
as
either
short-term
or
long-
term
capital
losses.
The
accumulated
capital
loss
carryover
is
available
for
federal
income
tax
purposes
to
be
applied
against
future
net
realized
capital
gains,
if
any,
realized
subsequent
to
October
31,
2023.
The
fund
has
$382,631
of
short-term
capital
losses
and
$744,298
of
long-term
capital
losses
which
can
be
carried
forward
for
an
unlimited
period.
The
tax
character
of
distributions
paid
to
shareholders
during
the
fiscal
years
ended
October
31,
2023
and
October
31,
2022
were
as
follows:
ordinary
income
$67,044
and
$354,
respectively.
NOTE
3—Management
Fee,
Sub-Advisory
Fee
and
Other
Transactions
with
Affiliates:
(a)
Pursuant
to
a
management
agreement
with
the
Adviser,
the
management
fee
is computed
at
an
annual
rate of
0.60%
of
the
value
of
the
fund’s
average
daily
net
assets
and
is
payable
monthly.
The
fund’s
management
agreement
provides
that
the
Adviser
pays
substantially
all
expenses
of
the
fund,
except
for
the
management
fees,
payments
under
the
fund’s
12b-1
plan
(if
any),
interest
expenses,
taxes,
acquired
fund
fees
and
expenses,
brokerage
commissions,
costs
of
holding
shareholder
meetings,
fees
and
expenses
associated
with
the
fund’s
securities
lending
program,
and
litigation
and
potential
litigation
and
other
extraordinary
expenses
not
incurred
in
the
ordinary
course
of
the
fund’s
business.
The
Adviser
may
from
time
to
time
voluntarily
waive
and/or
reimburse
fees
or
expenses
in
order
to
limit
total
annual
fund
operating
expenses.
Any
such
voluntary
waiver
or
reimbursement
may
be
eliminated
by
the
Adviser
at
any
time.
During
the
period
ended
October
31,
2023,
there
was
no
reduction
in
expenses
pursuant
to
the
undertaking.
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
22
In
addition,
the
Adviser
has
contractually
agreed,
from
March
1,
2023
through
March
1,
2024
to
waive
receipt
of
a
portion
of
its
management
fees
in
the
amount
of
0.10%
of
the
value
of
the
fund’s
average
daily
net
assets.
On
or
after
March
1,
2024,
the
Adviser
may
terminate
this
waiver
agreement
at
any
time.
The
reduction
in
expenses
pursuant
to
the
undertaking
amounted
to
$5,797
during
the
period
ended
October
31,
2023.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Sub-Adviser
serves
as
the
fund’s
sub-adviser
responsible
for
the
day-to-day
management
of
the
fund’s
portfolio.
The
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
percentage
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser
has
obtained
an
exemptive
order
from
the
SEC
(the
“Order”),
upon
which
the
fund
may
rely,
to
use
a
manager
of
managers
approach
that
permits
the
Adviser,
subject
to
certain
conditions
and
approval
by
the
Board,
to
enter
into
and
materially
amend
sub-investment
advisory
agreements
with
one
or
more
sub-advisers
who
are
either
unaffiliated
or
affiliated
with
the
Adviser
without
obtaining
shareholder
approval.
The
Order
also
relieves
the
fund
from
disclosing
the
sub-advisory
fee
paid
by
the
Adviser
to
a
Sub-Adviser
in
documents
filed
with
the
SEC
and
provided
to
shareholders.
In
addition,
pursuant
to
the
Order,
it
is
not
necessary
to
disclose
the
sub-advisory
fee
payable
by
the
Adviser
separately
to
a
Sub-Adviser
that
is
a
wholly-owned
subsidiary
(as
defined
in
the
1940
Act)
of
BNY
Mellon
in
documents
filed
with
the
SEC
and
provided
to
shareholders;
such
fees
are
to
be
aggregated
with
fees
payable
to
the
Adviser.
The
Adviser
has
ultimate
responsibility
(subject
to
oversight
by
the
Board)
to
supervise
any
Sub-Adviser
and
recommend
the
hiring,
termination,
and
replacement
of
any
Sub-Adviser
to
the
Board.
Pursuant
to
a
sub-investment
advisory
agreement
between
the
Adviser
and
the
Sub-
Adviser,
the
Adviser
pays
the
Sub-Adviser
a
monthly
fee
at
an
annual
rate
of
0.30%
of
the
value
of
the
fund’s
average
daily
net
assets.
The
Adviser,
and
not
the
fund,
pays
the
Sub-Adviser
fee
rate.
(b)
The
fund
has
an
arrangement
with
The
Bank
of
New
York
Mellon
(the
“Custodian”),
a
subsidiary
of
BNY
Mellon
and
an
affiliate
of
the
Adviser, whereby
the
fund
will
receive
interest
income
or
be
charged
overdraft
fees
when
cash
balances
are
maintained.
For
financial
reporting
purposes,
the
fund
includes
this
interest
income
and
overdraft
fees,
if
any,
as
interest
income
in
the
Statement
of
Operations.
The
components
of
“Due
to
BNY
Mellon
ETF Investment
Adviser,
LLC”
in
the
Statement
of
Assets
and
Liabilities
consist
of:
management
fee
of $4,368,
which
are
offset
against
an
expense
reimbursement
currently
in
effect
in
the
amount
of
$730.
23
(c)
Each
Board
member
serves
as
a
Board
member
of
each
fund
within
the
Trust.
The
Board
members
are
not
compensated
directly
by
the
fund.
The
Board
members
are
paid
by
the
Adviser
from
the
unitary
management
fee
paid
to
the
Adviser
by
the
fund.
The
quarterly
fees
are
paid
by
the
Adviser
from
unitary
management
fees
paid
to
the
Adviser
by
the
funds
within
the
Trust,
including
the
fund.
NOTE
4—Securities
Transactions:
The
aggregate
amount
of
purchases
and
sales
of
investment
securities,
excluding
short-term
securities
and
in-kind
transactions,
during
the
period
ended
October
31,
2023, amounted
to $3,050,879
and
$3,023,375,
respectively.
At October
31,
2023,
the
cost
of
investments
for
federal
income
tax
purposes
was
$8,917,298;
accordingly,
accumulated
net
unrealized
depreciation on
investments
for
federal
income
tax
purposes
was
$465,472,
consisting
of
gross
appreciation
of
$458,497
and
gross
depreciation
of
$923,969.
NOTE
5—Shareholder
Transactions:
The
fund
issues
and
redeems
its
shares
on
a
continuous
basis,
at
NAV,
to
certain
institutional
investors
known
as
“Authorized
Participants”
(typically
market
makers
or
other
broker-dealers)
only
in
a
large
specified
number
of
shares
called
a
Creation
Unit.
Except
when
aggregated
in
Creation
Units,
shares
of
the
fund
are
not
redeemable.
The
value
of
the
fund
is
determined
once
each
business
day.
The
Creation
Unit
size
for the
fund
may
change.
Authorized
Participants
will
be
notified
of
such
change.
Creation
Unit
transactions
may
be
made
in-kind,
for
cash,
or
for
a
combination
of
securities
and
cash.
The
principal
consideration
for
creations
and
redemptions
for
the
fund
is
in-kind,
although
this
may
be
revised
at
any
time
without
notice.
The
Trust
issues
and
sells
shares
of
the
fund
only:
in
Creation
Units
on
a
continuous
basis
through
the
Distributor,
without
a
sales
load,
at
their
NAV
per
share
determined
after
receipt
of
an
order,
on
any
Business
Day,
in
proper
form
pursuant
to
the
terms
of
the
Authorized
Participant
Agreement.
Transactions
in
capital
shares
for
the
fund
are
disclosed
in
detail
in
the
Statement
of
Changes
in
Net
Assets.
The
consideration
for
the
purchase
of
Creation
Units
of the
fund
may
consist
of
the
in-kind
deposit
of
a
designated
portfolio
of
securities
and
a
specified
amount
of
cash.
Investors
purchasing
and
redeeming
Creation
Units
may
pay
a
purchase
transaction
fee
and
a
redemption
transaction
fee
directly
to
the
Trust
and/or
custodian
to
offset
transfer
and
other
transaction
costs
associated
with
the
issuance
and
redemption
of
Creation
Units,
including
Creation
Units
for
cash.
The
Adviser
or
its
affiliates
(the
“Selling
Shareholder”)
may
purchase
Creation
Units
through
a
broker-dealer
to
“seed”
(in
whole
or
in
part)
funds
as
they
are
launched
or
may
purchase shares
from
broker-dealers
or
other
investors
that
have
previously
provided
“seed”
for
funds
when
they
were
launched
or
otherwise
in
secondary
market
transactions.
Because
the
Selling
Shareholder
may
be
deemed
an
affiliate
of
such
funds,
the
fund shares
are
being
registered
to
permit
the
resale
of
these
shares
from
time
to
time
after
purchase.
The
fund
will
not
receive
any
of
the
NOTES
TO
FINANCIAL
STATEMENTS
(continued)
24
proceeds
from
resale
by
the
Selling
Shareholders
of
these
fund
shares. An
additional
variable
fee
may
be
charged
for
certain
transactions.
Such
variable
charges,
if
any,
are
included
in
“Transaction
fees”
on
the
Statement
of
Changes
in
Net
Assets.
Seed
Capital:
As
of
October
31,
2023,
MBC
Investments
Corporation,
an
indirect
subsidiary
of
BNY
Mellon,
held
187,604
shares
of
the
fund.
In-kind
Redemptions:
For
financial
reporting
purposes,
in-kind
redemptions
are
treated
as
sales
of
securities
resulting
in
realized
capital
gains
or
losses
to
the
fund.
Because
such
gains
or
losses
are
not
taxable
to
the
fund
and
are
not
distributed
to
existing
fund
shareholders,
the
gains
or
losses
are
reclassified
from
accumulated
net
realized
gain
(loss)
to
paid-in
capital
at
the
end
of
the
fund’s
tax
year.
These
reclassifications
have
no
effect
on
net
assets
or
net
asset
value
per
share.
During
the
year
ended
October
31,
2023,
the
fund
had
no
in-kind
transactions.
REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
25
To
the
Shareholders
and
the
Board
of
Trustees
of
BNY
Mellon
Sustainable
US
Equity
ETF
Opinion
on
the
Financial
Statements
We
have
audited
the
accompanying
statement
of
assets
and
liabilities
of
BNY
Mellon
Sustainable
US
Equity
ETF
(the
“Fund”)
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust
(the
“Trust”)),
including
the
statement
of
investments,
as
of
October
31,
2023,
and
the
related
statement
of
operations
for
the
year
then
ended,
the
statements
of
changes
in
net
assets
and
the
financial
highlights
for
the
year
ended
October
31,
2023
and
the
period
from
December
15,
2021
(commencement
of
operations)
through
October
31,
2022
and
the
related
notes
(collectively
referred
to
as
the
“financial
statements”).
In
our
opinion,
the
financial
statements
present
fairly,
in
all
material
respects,
the
financial
position
of
the
Fund
(one
of
the
funds
constituting
BNY
Mellon
ETF
Trust)
at
October
31,
2023,
the
results
of
its
operations
for
the
year
then
ended,
and
the
changes
in
its
net
assets
and
its
financial
highlights
for
the
year
ended
October
31,
2023
and
the
period
from
December
15,
2021
(commencement
of
operations)
through
October
31,
2022,
in
conformity
with
U.S.
generally
accepted
accounting
principles.
Basis
for
Opinion
These
financial
statements
are
the
responsibility
of
the
Trust’s
management.
Our
responsibility
is
to
express
an
opinion
on
the
Fund’s
financial
statements
based
on
our
audits.
We
are
a
public
accounting
firm
registered
with
the
Public
Company
Accounting
Oversight
Board
(United
States)
("PCAOB")
and
are
required
to
be
independent
with
respect
to
the
Trust
in
accordance
with
the
U.S.
federal
securities
laws
and
the
applicable
rules
and
regulations
of
the
Securities
and
Exchange
Commission
and
the
PCAOB.
We
conducted
our
audits
in
accordance
with
the
standards
of
the
PCAOB.
Those
standards
require
that
we
plan
and
perform
the
audit
to
obtain
reasonable
assurance
about
whether
the
financial
statements
are
free
of
material
misstatement,
whether
due
to
error
or
fraud.
The
Trust
is
not
required
to
have,
nor
were
we
engaged
to
perform,
an
audit
of
the
Trust’s
internal
control
over
financial
reporting.
As
part
of
our
audits,
we
are
required
to
obtain
an
understanding
of
internal
control
over
financial
reporting
but
not
for
the
purpose
of
expressing
an
opinion
on
the
effectiveness
of
the
Trust’s
internal
control
over
financial
reporting.
Accordingly,
we
express
no
such
opinion.
Our
audits
included
performing
procedures
to
assess
the
risks
of
material
misstatement
of
the
financial
statements,
whether
due
to
error
or
fraud,
and
performing
procedures
that
respond
to
those
risks.
Such
procedures
included
examining,
on
a
test
basis,
evidence
regarding
the
amounts
and
disclosures
in
the
financial
statements.
Our
procedures
included
confirmation
of
securities
owned
as
of
October
31,
2023,
by
correspondence
with
the
custodian,
brokers
and
others;
when
replies
were
not
received
from
brokers
and
others,
we
performed
other
auditing
procedures.
Our
audits
also
included
evaluating
the
accounting
principles
used
and
significant
estimates
made
by
management,
as
well
as
evaluating
the
overall
presentation
of
the
financial
statements.
We
believe
that
our
audits
provide
a
reasonable
basis
for
our
opinion.
We
have
served
as
the
auditor
of
one
or
more
investment
companies
in
the
BNY
Mellon
Family
of
Funds
since
at
least
1957,
but
we
are
unable
to
determine
the
specific
year.
New
York,
New
York
December
20,
2023
IMPORTANT
TAX
INFORMATION
(Unaudited)
26
Form
1099-DIV,
Form
1042-S
and
other
year–end
tax
information
provide
shareholders
with
actual
calendar
year
amounts
that
should
be
included
in
their
tax
returns.
Shareholders
should
consult
their
tax
advisers.
The
following
distribution
information
is
being
provided
as
required
by
the
Internal
Revenue
Code
or
to
meet
a
specific
state’s
requirement.
The
fund
designates
the
following
amounts
or,
if
subsequently
determined
to
be
different,
the
maximum
amount
allowable
for
its
fiscal
year
ended October
31,
2023:
For
federal
tax
purposes
the
fund
hereby
reports
100.00%
of
ordinary
income
dividends
paid
during
the
fiscal
year
ended
October
31,
2023 as
qualified
dividend
income
and
corporate
dividends
received
deduction.
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
SUB-SUB-INVESTMENT
ADVISORY
AGREEMENT
(Unaudited)
27
At
a
meeting
held
May
9,
2023
(the
“May
Meeting”),
the
Board
of
Trustees
of
the
Trust
(the
“Board”),
all
the
members
of
which
are
not
“interested
persons”
of
the
Trust
as
defined
in
the
Investment
Company
Act
of
1940,
as
amended
(the
“1940
Act”),
considered
the
approval
of
a
delegation
arrangement
between
Newton
Investment
Management
Limited
(“NIM”
or
the
“Sub-Adviser”)
and
its
affiliate,
Newton
Investment
Management
North
America,
LLC
(“NIMNA”),
which
permits
NIM,
as
the
Sub-Adviser
to
BNY
Mellon
Sustainable
US
Equity
ETF
(the
“fund”),
to
use
the
investment
advisory
personnel,
resources
and
capabilities
(“Investment
Advisory
Services”)
available
at
its
sister
company,
NIMNA,
in
providing
the
day-
to-day
management
of
the
fund’s
investments.
In
connection
therewith,
the
Board
considered
the
approval
of
a
sub-sub-investment
advisory
agreement
(the
“SSIA
Agreement”)
between
NIM
and
NIMNA,
with
respect
to
the
fund.
The
Trustees
were
advised
by
legal
counsel
throughout
the
process.
The
Trustees
also
met
separately
from
management
to
consider
the
SSIA
Agreement.
NIM
and
NIMNA
are
affiliates
of
the
fund’s
investment
adviser,
BNY
Mellon
ETF
Investment
Adviser,
LLC
(the
“Adviser”).
At
the
May
Meeting,
the
Adviser
recommended
the
approval
of
the
SSIA
Agreement
to
enable
NIMNA
to
provide
Investment
Advisory
Services
to
the
Sub-Adviser
for
the
benefit
of
the
fund,
including,
but
not
limited
to,
portfolio
management
services,
subject
to
the
supervision
of
the
Sub-Adviser
and
the
Adviser.
The
recommendation
for
the
approval
of
the
SSIA
Agreement
was
based
on
the
following
considerations,
among
others:
(i)
approval
of
the
SSIA
Agreement
would
permit
the
Sub-Adviser
to
use
investment
personnel
employed
primarily
by
NIMNA
as
primary
portfolio
managers
of
the
fund
and
to
use
the
investment
research
services
of
NIMNA
in
the
day-to-day
management
of
the
fund’s
investments;
and
(ii)
there
would
be
no
material
changes
to
the
fund’s
investment
objective,
strategies
or
policies,
no
reduction
in
the
nature
or
level
of
services
provided
to
the
fund,
and
no
increases
in
the
management
fee
payable
by
the
fund
or
the
sub-advisory
fee
payable
by
the
Adviser
to
the
Sub-
Adviser
as
a
result
of
the
delegation
arrangement.
The
Board
noted
NIMNA
currently
serves
as
the
sub-adviser
for
certain
other
series
of
the
Trust,
and
had
presented
to
the
Board
at
a
meeting
held
on
February
8,
2023
(the
“February
Meeting”)
and
a
meeting
held
on
August
11,
2022
(the
“August
Meeting”)
with
respect
to
the
initial
approval
of
the
NIMNA
sub-advisory
agreement
with
respect
to
those
series.
The
Board
further
noted
NIMNA
had
represented
there
had
been
no
material
changes
to
the
information
it
had
provided
at
the
February
Meeting
and
August
Meeting.
In
approving
the
SSIA
Agreement,
the
Board
considered
the
materials
prepared
by
the
Adviser,
Sub-Adviser
and
NIMNA,
and
other
information
received
in
advance
of
the
May
Meeting,
which
included:
(i)
a
form
of
the
SSIA
Agreement
and
related
documents;
(ii)
information
regarding
the
delegation
arrangement
and
how
it
is
expected
to
enhance
investment
capabilities
for
the
benefit
of
the
fund;
(iii)
information
regarding
NIMNA;
and
(iv)
an
opinion
of
counsel
that
the
proposed
delegation
arrangement
would
not
result
in
an
“assignment”
of
the
Sub-Investment
INFORMATION
ABOUT
THE
APPROVAL
OF
THE
FUND’S
SUB-SUB-
INVESTMENT
ADVISORY
AGREEMENT
(Unaudited)
(continued)
28
Advisory
Agreement
under
the
1940
Act
and
the
Investment
Advisers
Act
of
1940,
as
amended,
and,
therefore,
did
not
require
the
approval
of
fund
shareholders.
The
Board
also
considered
materials
provided
by
the
Adviser,
Sub-Adviser
and
NIMNA
received
in
advance
of:
(i)
the
February
Meeting,
in
connection
with
the
Board’s
re-approval
of
the
Management
Agreement
between
the
Trust
and
the
Adviser,
pursuant
to
which
the
Adviser
provides
the
fund
with
investment
advisory
and
administrative
services,
and
the
Sub-Investment
Advisory
Agreement
between
the
Adviser
and
Sub-Adviser,
pursuant
to
which
the
Sub-Adviser
provides
day-to-day
management
of
the
fund’s
investments;
and
(ii)
the
February
Meeting
and
August
Meeting,
in
connection
with
the
Board’s
initial
approval
of
the
NIMNA
sub-investment
advisory
agreement
with
respect
to
the
other
series
of
the
Trust
for
which
NIMNA
serves
as
a
sub-adviser.
The
Board
also
took
into
consideration
the
substance
of
discussions
with
representatives
of
the
Adviser,
Sub-Adviser
and
NIMNA
at
the
May
Meeting,
February
Meeting
and
August
Meeting.
BOARD
MEMBERS
INFORMATION
(Unaudited)
INDEPENDENT
BOARD
MEMBERS
29
J.
Charles
Cardona
(67)
Chairman
of
the
Board
(2020)
Principal
Occupation
During
Past
5
Years:
BNY
Mellon
Family
of
Funds,
Interested
Director
(2014-2018),
Independent
Director
(2019-Present)
BNY
Mellon
Liquidity
Funds,
Director
(2004-Present)
and
Chairman
(2019-2021)
No.
of
Portfolios
for
which
Board
Member
Serves:
38,
including
22
managed
by
an
affiliate
of
the
Adviser
Kristen
M.
Dickey
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Independent
board
director
of
Marstone,
Inc.,
a
financial
technology
company
(since
2018);
Lead
non-executive
director
for
Aperture
Investors,
LLC,
an
investment
management
firm
(since
2018);
Managing
Director—Global
Head
of
Index
Strategy
at
BlackRock,
Inc.
(until
2017).
No.
of
Portfolios
for
which
Board
Member
Serves:
16
F.
Jack
Liebau,
Jr.
(60)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
Director
at
Beach
Investment
Counsel,
a
financial
advisory
firm
(since
2020)
Corporate
director
(since
2015)
Other
Public
Company
Board
Memberships
During
Past
5
Years:
Myers
Industries,
an
industrial
company,
Director
(2015
–
Present;
Chairman
of
Board
2016
–
Present)
No.
of
Portfolios
for
which
Board
Member
Serves:
16
Jill
I.
Mavro
(51)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Managing
director
at
CapWGlobal,
LLC,
a
financial
technology
consulting
company
(since
2020)
Founder
and
Principal
of
Spoondrift
Advisory,
LLC
(since
2018);
Senior
Managing
Director,
Head
of
Strategic
Relationships
and
Member
of
SPDR
Executive
Committee
at
State
Street
Global
Advisors
(until
2018)
No.
of
Portfolios
for
which
Board
Member
Serves:
16
30
BOARD
MEMBERS
INFORMATION
(Unaudited)
(continued)
INDEPENDENT
BOARD
MEMBERS
Kevin
W.
Quinn
(64)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Partner
at
PricewaterhouseCoopers,
LLC
(until
2019)
No.
of
Portfolios
for
which
Board
Member
Serves:
16
Stacy
L.
Schaus
(63)
Board
Member
(2020)
Principal
Occupation
During
Past
5
Years:
Chief
Executive
Officer
of
the
Schaus
Group
LLC,
a
consulting
firm
(since
2019);
Advisory
board
member
of
A&P
Capital,
a
consulting
firm
(from
2019-2021);
Executive
Vice
President—Defined
Contribution
Practice
Founder
at
PIMCO
Investment
Management
(until
2018).
No.
of
Portfolios
for
which
Board
Member
Serves:
16
The
address
of
the
Board
Members
and
Officers
is
c/o
BNY
Mellon
ETF
Investment
Adviser,
LLC,
240
Greenwich
Street,
New
York,
New
York
10286.
Additional
information
about
each
Board
Member
is
available
in
the
fund’s
Statement
of
Additional
Information
which
can
be
obtained
from
the
Adviser
free
of
charge
by
calling
this
toll
free
number:
1-833-383-2696.
OFFICERS
OF
THE
TRUST
(Unaudited)
31
DAVID
DIPETRILLO,
President
since
February
2020.
Vice
President
and
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2021;
Head
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
February
2023;
Head
of
North
America
Product,
BNY
Mellon
Investment
Management
from
January
2018
to
February
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
102
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
45
years
old
and
has
been
an
employee
of
BNY
Mellon
since
2005. 
PETER
M.
SULLIVAN,
Chief
Legal
Officer
since
July
2021,
Vice
President
and
Assistant
Secretary
since
February
2020.
Chief
Legal
Officer
of
BNY
Mellon
Investment
Adviser,
Inc.
and
Associate
General
Counsel
of
BNY
Mellon
since
July
2021;
Senior
Managing
Counsel
of
BNY
Mellon
from
December
2020
to
July
2021;
and
Managing
Counsel
of
BNY
Mellon
from
March
2009
to
December
2020.
He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
since
April
2004.
JAMES
WINDELS,
Treasurer
since
February
2020.
Director
of
BNY
Mellon
Investment
Adviser,
Inc.
since
February
2023;
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
September
2020;
and
Director
–
BNY
Mellon
Fund
Administration.
 He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
65
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1985.
SARAH
S.
KELLEHER,
Vice
President
and
Secretary
since
February
2020.
Vice
President
of
BNY
Mellon
ETF
Investment
Adviser,
LLC
since
February
2020;
Senior
Managing
Counsel
of
BNY
Mellon
since
September
2021;
and
Managing
Counsel
of
BNY
Mellon
from
December
2017
to
September
2021. 
She
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
She
is
48
years
old
and
has
been
an
employee
of
BNY
Mellon
since
March
2013.
JAMES
BITETTO,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon
since
December
2019;
Managing
Counsel
of
BNY
Mellon
from
April
2014
to
December
2019;
and
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
57
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
December
1996.
DEIRDRE
CUNNANE,
Vice
President
and
Assistant
Secretary
since
February
2020.
Managing
Counsel
of
BNY
Mellon
since
December
2021;
and
Counsel
of
BNY
Mellon
from
August
2018
to
December
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
32
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
August
2018.
JEFF
PRUSNOFSKY,
Vice
President
and
Assistant
Secretary
since
February
2020.
Senior
Managing
Counsel
of
BNY
Mellon.
He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
58
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
October
1990.
AMANDA
QUINN,
Vice
President
and
Assistant
Secretary
since
February
2020.
Counsel
of
BNY
Mellon
since
June
2019;
and
Regulatory
Administration
Manager
at
BNY
Mellon
Investment
Management
Services from
September
2018
to
May
2019.
She
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
June
2012.
JOANNE
SKERRETT,
Vice
President
and
Assistant
Secretary
since
March
2023.
Managing
Counsel
of
BNY
Mellon
since
June
2022;
and
Senior
Counsel
with
the
Mutual
OFFICERS
OF
THE
TRUST
(Unaudited)
(continued)
32
Fund
Directors
Forum,
a
leading
funds
industry
organization,
from
2016
to
June
2022. 
She
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
51
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
2022.
DANIEL
GOLDSTEIN,
Vice
President
since
March
2022
Head
of
Product
Development
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023;
and
Senior
Vice
President,
Development
&
Oversight
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
102
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
54
years
old
and
has
been
an
employee
of
the
Distributor
since
1991.
JOSEPH
MARTELLA,
Vice
President
since
March
2022
Vice
President
of
BNY
Mellon
Investment
Adviser,
Inc.
since
December
2022;
Head
of
Product
Management
of
North
America
Distribution,
BNY
Mellon
Investment
Management
since
January
2018;
Executive
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
since
April
2023,
and
Senior
Vice
President
of
North
America
Product,
BNY
Mellon
Investment
Management
from
2010
to
March
2023.
He
is
an
officer
of
53
investment
companies
(comprised
of
102
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
He
is
47
years
old
and
has
been
an
employee
of
the
Distributor
since
1999.
GAVIN
C.
REILLY,
Assistant
Treasurer
since
February
2020.
Tax
Manager-BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
55
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
April
1991.
ROBERT
SALVIOLO,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
June
1989.
ROBERT
SVAGNA,
Assistant
Treasurer
since
February
2020.
Senior
Accounting
Manager
–
BNY
Mellon
Fund
Administration.
He
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser. 
He
is
56
years
old
and
has
been
an
employee
of
BNY
Mellon
Investment
Adviser,
Inc.,
an
affiliate
of
the
Adviser,
since
November
1990.
NATALYA
ZELENSKY,
Vice
President
and
Assistant
Secretary
since
February
2020
and
Chief
Compliance
Officer
since
August
2021.
Chief
Compliance
Officer
since
August
2021
and
Vice
President
since
February
2020
of
BNY
Mellon
ETF
Investment
Adviser,
LLC;
Managing
Counsel
of
BNY
Mellon
from
December
2019
to
August
2021;
Counsel
of
BNY
Mellon
from
May
2016
to
December
2019;
and
Assistant
Secretary
of
BNY
Mellon
Investment
Adviser,
Inc.
from
April
2018
to
August
2021.
She
is
an
officer
of
54
investment
companies
(comprised
of
121
portfolios)
managed
by
the
Adviser or
an
affiliate
of
the
Adviser.
She
is
38
years
old
and
has
been
an
employee
of
BNY
Mellon
since
May
2016.
CARIDAD
M.
CAROSELLA,
Anti-Money
Laundering
Compliance
Officer
since
February
2020.
Anti-Money
Laundering
Compliance
Officer
of
the
BNY
Mellon
Family
of
Funds
and
BNY
Mellon
Funds
Trust.
She
is
an
officer
of
47
investment
companies
(comprised
of
114
portfolios)
managed
by
the
Adviser
or
an
affiliate
of
the
Adviser.
She
is
55
years
old
and
has
been
an
employee
of
the
Distributor
since
1997.
For
More
Information
2023
BNY
Mellon
Securities
Corporation
4861AR1023
Telephone
Call
your
financial
representative
or
1-833-ETF-BNYM
(383-2696)
(inside
the
U.S.
only)
Mail
BNY
Mellon
ETF
Trust,
240
Greenwich
Street,
New
York,
New
York
10286
E-Mail
Send
your
request
to
[email protected]
Internet
Information
can
be
viewed
online
or
downloaded
at
www.im.bnymellon.com
BNY
Mellon
ETF
Trust
discloses,
at
www.im.bnymellon.com
,
the
identities
and
quantities
of
the
securities
held
by
the
fund
daily.
The
fund
files
its
complete
schedule
of
portfolio
holdings
with
the
Securities
and
Exchange
Commission
(
“
SEC
”
)
for
the
first
and
third
quarters
of
the
fiscal
year
on
Form
N-PORT.
The
fund
’
s
Forms
N-PORT
are
available
on
the
SEC
’
s
website
at
www.sec.gov
.
Additionally,
the
fund
makes
its
portfolio
holdings
for
the
first
and
third
quarters
of
the
most
recent
fiscal
year
available
at
https://im.bnymellon.com/etfliterature
.
The
fund
’
s
complete
schedule
of
portfolio
holdings,
as
filed
on
Form
N-PORT,
can
also
be
obtained
without
charge,
upon
request,
by
calling
1-833-383-2696.
A
description
of
the
policies
and
procedures
that
the
fund
uses
to
determine
how
to
vote
proxies
relating
to
portfolio
securities,
and
information
regarding
how
the
fund
voted
these
proxies
for
the
most
recent
12-month
period
ended
June
30
is
available
at
www.im.bnymellon.
com
and
on
the
SEC’s
website
at
www.sec.gov
.
The
description
of
the
policies
and
procedures
is
also
available
without
charge,
upon
request,
by
calling
1-833-383-2696.
BNY
Mellon
ETF
Trust
Custodian
BNY
Mellon
ETF
Investment
Adviser,
LLC
240
Greenwich
Street
New
York,
NY
10286
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Adviser
Transfer
Agent
&
Dividend
Disbursing
Agent
BNY
Mellon
ETF
Investment
Adviser,
LLC
201
Washington
Street
Boston,
MA
02108
The
Bank
of
New
York
Mellon
240
Greenwich
Street
New
York,
NY
10286
Sub-Adviser
Distributor
Newton
Investment
Management
Limited
160
Queen
Victoria
Street
London,
EC4V,
4LA,
UK
BNY
Mellon
Securities
Corporation
240
Greenwich
Street
New
York,
NY
10286
Ticker
Symbol:
BNY
Mellon
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