Income taxes

3. You disclose on page 110 that the increase in the provision for income taxes for the year ended December 31, 2025 was primarily due to the establishment of a valuation U.S. Securities and Exchange Commission June 3, 2026 Page 3 allowance in 2025 as a result of the enactment of the One Big Beautiful Bill Act. However, on page F-51, you attribute the establishment of the valuation allowance in 2025 to cumulative pretax losses and other negative evidence. Please revise as needed to clarify this inconsistency.

12. We note your response to prior comment 20. For all periods presented, please revise to address the underlying reasons for changes in your provision for (benefit from) income taxes. For example, it is unclear why you recognized a substantial valuation allowance during 2025 but released a partial valuation allowance against net deferred tax assets in 2024.

2. We note that in your table of selected financial data by business segment, you have a column titled “Corporate and Other” and that this column consists of general and administrative overhead costs and unallocated expenses related to stock-based compensation and purchased intangible amortization, which are not used in evaluating the results of, or in the allocation of resources to, your reportable segments. As this amount appears to represent the reconciling items between the total of the gross margin segment measures and your consolidated gross margin, rather than revenue/expenses related to other segments, it should not be given prominence as a separate column, but instead should be reflected as a reconciling item in a reconciliation which totals the segment profitability measures and reconciles to consolidated income before income taxes. Refer to the guidance in ASC 280-10-50-30.…

1. We note that you disclose on the cover page, as well as elsewhere in the registration statement, that you may withdraw funds from the trust account in order to make income tax payments. We note that in Section 1(j) of the trust agreement indicates that any withdrawal from the trust in order to pay income taxes is limited to “interest earned on the (p)roperty.” Revise to clarify, if true, that your ability to make withdrawals from the trust account is limited and cannot reduce the $10 per share deposited as part of this transaction.

2. Please quantify the components included in your tax specific adjustments and tell us your purpose for including these adjustments in your non-GAAP measure presentation. Please explain why these adjustments do not substitute individually tailored recognition and measurement methods for those of GAAP. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. The Company acknowledges the Staff’s comment and set forth below is a discussion of the Company’s purpose for including the tax specific adjustments in our non-GAAP measure presentation. In the future, the Company will quantify the significant components of tax specific adjustments that have multiple components to the extent material to the adjustment, as illustrated at the end of this response for fiscal years ended December 29, 2024 (“fiscal 2024”) and December 31, 2023 (“fiscal 2023”)…

Comment: It appears the increase of $82.8 million in cash paid for income taxes, net of refunds, in fiscal 2024 compared to fiscal 2023 is a material item that is not disclosed as a factor in your analysis of changes in operating cash flows. Please discuss all material usages of cash as appropriate. Refer to Item 303(a) and (b) of Regulation S-K. Additionally, quantify each variance factor cited in annual and interim period reports.

4. Please provide reconciliations of the totals of your reportable segments' measures of profit or loss to your consolidated income before income taxes, in accordance with ASC 280-10-50-28C and 50-30(b).

3. We note your disclosure in Note 20 of each segment’s profitability measure of Adjusted EBITDA. We further note that you disclose a total for these amounts less unallocated corporate expenses to arrive at a total Adjusted EBITDA amount. This amount is reconciled to net income immediately prior to the disclosure. Please note that ASC 280-10-50-30(b) requires a reconciliation which begins with the total of the reportable segment profitability measures and reconciles to your consolidated income before income taxes and discontinued operations. In providing this reconciliation, unallocated corporate expenses would be considered a reconciling item below the total of segment Adjusted EBITDA. Please revise your reconciliation accordingly. See example of a reconciliation in ASC 280-10-55-48.

4. Please address the following as they relate to adjusted diluted net loss per share in prior comment 4: • Confirm that you will disclose prior year comparative information; • Confirm that you will disclose, at a similar level as you provided in your response letter dated September 18, 2025, the reasons why management believes that adjusting for income/loss relating to equity method securities and the gain/loss on debt securities carried at fair value in arriving at adjusted diluted net loss per share provides useful information to investors; and • Confirm that you will present the income tax effect separately from other non-GAAP adjustments as it does not appear that you have done so in your September 30, 2025 earnings release. Company

1. Please further revise your proposed disclosure to remove the exclusion of Hong Kong and Macau from the definition of “PRC” and “China.” Revise to clearly state that all the legal and operational risks associated with having operations in the People’s Republic of China (PRC) also apply to operations and entities in Hong Kong and Macau. This disclosure could appear in the definition itself or in an appropriate discussion of legal and operational risks. To the extent you do not have material operations in Hong Kong and/or Macau, as you indicate in your response, you may provide disclosure to this effect. However, we also note that you have two Hong Kong intermediate holding companies in your corporate structure and disclose income before taxes attributable to Hong Kong for fiscal year 2024 in your income tax disclosure on page F-49. Please provide us with proposed revised disclosures in…

Comment : We note that your discussion of tax consequences is based on the assumption that the Fund will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion of counsel as to grantor trust status and describe the reasons for and level of any uncertainty, if applicable.

Comment 6 : United States Federal Income Tax Consequences, page 121: We note that your discussion of tax consequences is based on the assumption that the Trust will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion as to the tax consequences and describe the reasons for and level of any uncertainty associated with grantor trust status.

Comment 1 : The Staff notes that the fee table in the Fund’s currently effective prospectus dated March 31, 2025 includes an amount of 0.00% for the Fund’s Income Tax Expense line item, whereas in the Fund’s prospectus dated March 31, 2022 (and for prior years), the Fund disclosed a positive amount of Income Tax Expense within the fee table. The Staff notes that Form N-1A, Item 3, Instruction 3(c) provides, in part, that “‘Other Expenses’ include all expenses not otherwise disclosed in the table that are deducted from the Fund’s assets or charged to all shareholder accounts.” Please explain why any Income Tax Expense amounts are not currently included in the fee table in the Fund’s currently effective prospectus, but are discussed in an associated footnote. Please also confirm whether the Fund’s Total Annual Fund Operating Expenses, including the Fund’s Income Tax Expense, is…

Comment 8 – Form N-CSR – Notes to Consolidated Financial Statements – Income Tax Information and Distributions to Shareholders Please supplementally explain why the tax-basis components of dividends paid (ordinary income distributions, long-term capital gains distributions and return of capital distributions) disclosure is not included pursuant to FASB ASC 946-505-50-5. The Staff notes that the disclosure should reflect the two most recent fiscal year-ends .

2. You attribute the decrease in reported cash provided by operating activities in fiscal 2024 compared to fiscal 2023 of $95.6 million solely to an increase in your inventory purchases, which appears to be about $57 million based on the change between 2024 and 2023 in the line Rental Merchandise reported in the statement of cash flows. Based on changes in amounts reported in the statement of cash flows, it appears other factors materially affected the change in operating cash flows between these periods that have not been discussed. For example, net earnings/loss, adjusted for adjustments to reconcile net earnings (loss) to net cash provided by operating activities, increased $120 million, negative impact in the sum of receivables, accounts payable - trade and accrued liabilities aggregating $157 million and increase in income taxes paid, net of refunds, of $34 million. Refer to item…

5. Please reconcile the total of the reportable segments' amount for each measure of profit or loss to your consolidated income/loss before income taxes and discontinued operations or consolidated net income/loss as appropriate. Refer to ASC 280-10-50-30.b.

Comment : We note that your discussion of tax consequences is based on the assumption that the Fund will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion of counsel as to grantor trust status and describe the reasons for and level of any uncertainty, if applicable.

7. Management’s Discussion and Analysis of Financial Condition and Results of Operations” focuses on current year results as opposed to results from the prior year. Please see the section titled “Operations” in attached Annex A for an example of the Company’s planned disclosure. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance Office of Energy & Transportation October 10, 2025 Page 3 Non-GAAP Performance Measures, page 27 7. We note your presentation of a non-GAAP financial measure titled ‘Free Cash Flow’. Please address the following: · You identify Free Cash Flow as performance measure, but the label suggests it may be a liquidity measure. Tell us the specific facts and circumstances that led you to conclude this is a performance measure. If you continue to believe Free Cash Flow is a performance measure, tell us how you determined it is…

2. Please disclose the amounts for interest and income taxes paid for the six months ended June 30, 2025 and 2024. Refer to ASC 230-10-50-2 and 2A.

Comment: The Staff notes that, for Franklin Municipal High Yield ETF, the “Fund summary – Principal investment strategies” section includes a description of “tax-exempt investments” for purposes of the Fund’s 80% policy ( i.e. , “[s]uch tax-exempt investments in which the fund invests are issued by or for states, territories or possessions of the United States or by their political subdivisions, agencies, authorities or other government entities, and the income from these investments is exempt from federal income tax.”). The Staff notes that similar disclosure for Putnam Municipal Income ETF and Franklin Short-Term Municipal Income ETF instead appears in the section “Fund details – Principal investment risks” under the heading “Tax-exempt investments.” Please consider using a consistent description of tax-exempt investments across these three Funds and please include the disclosure in…

2. We note the tax opinion filed as Exhibit 8.1 provides that the discussion set forth in the Prospectus under the heading “Material U.S. Federal Income Tax Considerations,” insofar as it describes provisions of U.S. federal income tax law and Regulations or legal conclusions with respect thereto, constitutes, in all material respects, an accurate summary under current law of the material U.S. federal income tax considerations. Your tax opinion should identify the specific tax issue on which counsel is opining and not merely be an opinion on the manner in which they are described in the prospectus. Refer to Section III.C.1 of Staff Legal Bulletin for guidance. Please revise.

Comment: In the section “Fund summary – Principal investment strategies”, please clarify the meaning of the term “tax-exempt investments” as used in the Fund’s 80% policy, specifically noting that the investments are exempt from federal income tax.

Comment: The Staff notes that, for Franklin Municipal Income ETF, disclosure under “Tax-exempt investments” in the section “Fund Details – Principal Investment Risks” states that tax-exempt investments are “exempt from both federal and the applicable state’s income tax” and that, for Franklin Municipal High Yield ETF and Franklin Short-Term Municipal Income ETF, comparable disclosure in the same section states that such investments are “exempt from federal income tax” (with no reference to the applicable state’s income tax). Please reconcile or confirm that this difference is intentional.

Comment: Please consider updating the first sentence under “Tax-exempt investments” in the section “Fund details – Principal investment risks” to references both New York State and New York City income tax.

Comment: In correspondence, please provide an accounting analysis citing relevant U.S. GAAP and other relevant guidance and pronouncements supporting the non-recognition of a valuation allowance on a portion or all of the deferred tax assets of $4,285,489 for future tax benefits disclosed in “Note 10: Income Taxes” in the financial statements for the fiscal year ended December 31, 2024. In your response, please cite all positive and negative evidence assessed to determine that it is more likely than not that future taxable income will be sufficient to fully or partially realize the deferred tax asset for net operating loss carryforwards. Staff notes that substantially all of the $16.7 million in federal net operating losses were realized in the 2021 tax year and the balance has remained relatively static in the intervening three years. Staff also notes that ASC 740-10-30-21 states that…

4. Please address the following as they relate to adjusted diluted net loss per share: • Revise your description on page 8 of the adjusted diluted net loss per share calculation to include the adjustment for gain/loss on debt securities carried at fair value. • Tell us why you only present this measure for the most recent period, while you presumably utilize this measure for a period-to-period comparison. • Tell us and disclose in greater detail the reasons why management believes that adjusting for income/loss relating to equity method securities and the gain/loss on debt securities carried at fair value in arriving at adjusted diluted net loss per share provides useful information to investors. • In your Item 2.02 Form 8-K for the period ended December 31, 2023, it appears you previously had adjusted for write-downs of assets held for sale. Tell us why you do not adjust for…

2. We note that on December 29, 2023, you sold your 100% equity interest in Jikang Energy and Tantech Bamboo for consideration of $0.7 million and recognized a gain of $3.6 million that positively impacted income before income tax for fiscal year 2023 by 38.5%. Please tell us and expand your disclosures to explain why you have not reflected the consideration in your statement of cash flows and the facts and circumstances that led to the recognition of the gain. Confirm that you will provide the disclosures required by ASC 360-10-50-3 and 50-3A for this transaction.

Comment: Please revise to include a fundamental policy: (1) to invest, under normal circumstances, at least 80% of the value of the Fund’s asset in investments the income from which is exempt, as applicable, from federal income tax or from both federal and state income tax; or (2) to invest, under normal circumstance, its assets so that at least 80% of the income that is distributed will be exempt, as applicable, from federal income tax, or from both federal and state income tax.

Comment 15. Please discuss in the paragraph on page 37 titled, “Summary of the Material U.S. Federal Income Tax Consequences of the Reorganization” the extent that investors in the Target Funds may experience significant tax consequences as a result of the repositioning to prepare for the Reorganizations.

Comment : The Prospectus section titled “Summary of the Fund – Principal Investment Strategies” states that “Under normal circumstances, the Fund invests at least 80% of its net assets, plus the amount of any borrowings for investment purposes, in municipal bonds that are exempt from federal income tax.” Please revise this disclosure to clarify that, pursuant to Rule 35d-1(a)(3)(i)(A) or (B) under the Investment Company Act of 1940, as amended (the “1940 Act”), it is the income from the municipal bonds, rather than the municipal bonds themselves, that is exempt from federal income tax.

1. We note that your tabular disclosures of segment information beginning on page 101 include columns for each of the reportable segments, as well as columns for “Corporate” and “Eliminations/Reclassifications”, which are added to arrive at a “Total” column. This presentation appears to result in a total Earnings (loss) before interest and taxes - adjusted amount, inclusive of Corporate. Please revise to reconcile the total of the reportable segments’ measures of profit or loss to consolidated income before income taxes. Refer to ASC 280-10-50-30(b). In this regard, the reconciliation should include a single amount for the subtotal of the reportable segments’ measures of profit or loss with a reconciliation of that amount to consolidated income before income taxes. Similarly, please revise to reconcile other totals of reportable segments’ amounts, such as revenues, assets, and…

22. We note your disclosure addresses only “certain” material U.S. federal income tax consequences. Please revise your disclosure throughout the proxy statement/prospectus to clarify that you are addressing the material U.S. federal income tax consequences as opposed to “certain” material U.S. federal income tax consequences. For guidance, please refer to Section III.C.1 of Staff Legal Bulletin 19.

5. Operating and Financial Review and Prospects, page 41 Please more fully explain to us and revise future filings to address the following items. ● Explain the specific reasons for the declines in product volumes during the periods presented and address the factors impacting this trend. ● Explain how the exchange gains and losses are determined for each period, including the assets, liabilities and/or transactions they relate to, and explain the reasons for changes in such amounts during the periods presented. ● Explain the reasons for the decrease in the effective income tax rate for FY 24 and clarify whether you anticipate the decrease is indicative of a trend in future effective income tax rates. Refer to Item 5 of Form 20-F.

Comment 6: United States Federal Income Tax Consequences, page 121: We note that your discussion of tax consequences is based on the assumption that the Trust will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion as to the tax consequences and describe the reasons for and level of any uncertainty associated with grantor trust status.

Comment 7: United States Federal Income Tax Consequences, page 121: Please revise this section and your risk factors to address the tax consequences of the Trust's staking program.

3. Comment : We note your response to prior comment 16. We also note that your discussion of tax consequences is still based on the assumption that the Fund will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion of counsel as to the tax consequences and describe the reasons for and level of any uncertainty associated with grantor trust status.

5. We note that the Other Adjustments amount of $9.3 million in your federal income tax reconciliation for 2024 exceeds your statutory income tax expense of $1.1 million and represents 184% of income before tax in 2024. Please expand your disclosure to describe the composition of this item to include identifying and quantifying any components that exceed five percent of the statutory amount.

4. Please revise to reconcile the total of the reportable segments’ amount for each measure of profit or loss to consolidated income before income taxes. Refer to ASC 280-10-50-30(b) and ASC 280-10-50-28C. The reconciliation should include a single amount for the subtotal of the reportable segments’ measures of profit or loss with a reconciliation of that amount to consolidated income before income taxes. In this regard, we note that the segment note currently includes a Corporate/Elimination column which appears to result in the presentation of non-GAAP measures of consolidated EBIT and consolidated Adjusted EBIT. Please similarly revise to reconcile to the total reportable segments’ amounts to consolidated amounts, such as the total of the reportable segments’ assets to consolidated assets. Refer to ASC 280-10-50-30.

13. We note that Jiangxi Jiabin declared dividends of RMB28,434,060 and RMB18,947,000 to Jiabin HK in October and November 2024, respectively, and these dividends were subject to a 5% withholding tax in accordance with the PRC-Hong Kong Double Tax Treaty. We also note the Group did not provide for deferred income taxes and withholding taxes on the undistributed earnings of PRC subsidiaries during the two years ended December 31, 2024. ASC 740-30-25-17 requires a parent entity to have evidence of specific plans to support the assertion that the indefinite reversal criteria are met. Tell us the specifically documented plans for reinvestment during the two year period to support your assertion that the remittance of the earnings will be postponed indefinitely. Explain what occurred, when it became apparent that some or all of the undistributed earnings of your subsidiary would be remitted…

14. You disclose on page 5 that the Group’s declaration of dividends was a one-off event and you intend to keep any remaining undistributed earnings and future earnings for the foreseeable future. Tell us how you continue to assert the indefinite reinvestment of undistributed past and future earnings and why you are not required to record a deferred tax liability for any taxable temporary differences to measure the tax effect of an outside basis difference. Include the amount of undistributed earnings for the PRC subsidiaries which income taxes have not been provided for, as of December 31, 2024.

Comment: In the Q & A section, the response to the Question regarding whether the value of a shareholders investment will change as a result of the approval of the proposed Reorganization states that, “The Reorganization of the Target Fund generally is not expected to result in the recognition of material gain or loss by Target Fund or its shareholders for federal income tax purposes.” Elsewhere in the N-14 it states that no gain or loss will be realized. Please harmonize, and to the extent there may be gain or loss, please supplementally advise under what circumstances that would happen.

Comment : Please apply the preceding comment to the fifth paragraph after the bulleted list in the Federal Income Tax Consequences regarding capital loss carryforwards.

Comment : According to relevant disclosure, some of the investments that the Fund is expected to make, such as investments in debt instruments having market discount and/or treated as issued with original issue discount (“OID”), may cause the Fund to recognize income or gain for U.S. federal income tax purposes prior to the receipt of any corresponding cash or other property. Please confirm that the corresponding risks are disclosed.

17. Comment: In the discussion under the heading “Federal Income Tax Consequences” in the section “V. Information about the Mergers,” please consider stating that each Merger will be a tax-free reorganization.

Comment 32 – United States Federal Income Tax Consequences, page 104 The Staff notes that your discussion of tax consequences is based on the assumption that the Fund will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion as to the tax consequences and describe the reasons for and level of any uncertainty associated with grantor trust status. In addition, please revise this section and your risk factors to address the tax consequences of the Fund’s staking program.

Comment 33 – United States Federal Income Tax Consequences – Taxation of U.S. Shareholders, page 105 The Staff notes your disclosure that Authorized Participants may request an in-kind distribution of Trust assets when an Authorized Participant redeems its Shares at any time prior to 30 business days before the Trust’s termination date “if permitted.” Please revise your disclosure to clarify what is meant by “if permitted.”

3. We note that in your table of segment results, you have a column titled “All Other” and that this column includes the expenses that are not allocated to either Compute & Networking or Graphics for purposes of making operating decisions or assessing financial performance. As this amount appears to represent the reconciling items between the total of the operating income segment measures and your consolidated operating income, rather than revenue/expenses related to other segments, it should not be given prominence as a separate column, but instead should be reflected as a reconciling item in a reconciliation which totals the segment profitability measures and reconciles to consolidated income before income taxes. See guidance in ASC 280-10-50-30. Please revise your disclosure in future filings.

16. Please expand this risk factor to discuss how holding liquid staking tokens, and the Trust’s staking activities in general, could affect the Trust’s ability to qualify as a grantor trust for U.S. federal income tax purposes. In this regard we note your disclosure at the end of the second paragraph that “[i]f the Trust were treated as owning any asset other than SOL as of any date on which it creates or redeems Shares, it may likely cease to qualify as a grantor trust for U.S. federal income tax purposes.”

22. We note that your discussion of tax consequences is based on the assumption that the Fund will be treated as a grantor trust for U.S. federal income tax purposes. Please revise to provide an opinion as to the tax consequences and describe the reasons for and level of any uncertainty associated with grantor trust status.

Comment 6: United States Federal Income Tax Consequences – Taxation of the Trust, page 19. Please revise your disclosure to specify whether you will receive an opinion from counsel regarding the classification of the Trust as a grantor trust for U.S. federal income tax purposes.

1. As the term “discrete tax benefits” could refer to a variety of situations giving rise to adjustments to your income taxes during the quarter, please revise your upcoming Form 10-Q to explain in reasonable detail the nature of and amounts related to each type of material discrete tax benefit that contributed to the fluctuation in your effective tax rate. Please include your proposed future disclosure with your response.

Comment 3. With respect to Lazard Global Infrastructure ETF’s investment in MLPs, please include current income tax expense and/or deferred income tax expense lines in the Portfolio’s fee and expense table.

Comment 5. With respect to Lazard Global Infrastructure ETF’s investment in MLPs, please include a tax risk that discloses the following: a) if the Portfolio retains a MLP investment until its basis is reduced to zero, subsequent distributions from the MLP will be taxable to the Portfolio at ordinary income tax rates; b) if a MLP that the Portfolio enlists amends its partnership tax returns, shareholders may receive a corrected Form 1099 from the Portfolio, which may require shareholders to amend their own federal, state or local tax returns; and c) if the Portfolio invests in equity interests of MLPs, please confirm if that includes general partner (“GP”) interests in the MLP.

3. We note you appropriately present pro forma income tax disclosures here and address the impact of becoming a taxable entity in MD&A; however, we also note you revised your historical combined statements of operations on pages F-3 and F-26 to include pro forma income tax disclosures in response to prior comment 6. Please remove pro forma income tax disclosures from the faces of your historical financial statements. Refer to Rule 11-02(a)(12)(i) of Regulation S-X.

Comment 28 . Also on page 20, under the heading “Federal Income Taxes”, please revise the second sentence to say that the legal opinion will reflect that the Reorganization “will” qualify as a tax-free reorganization rather than “should” qualify.

Comment 4. Please supplementally confirm if there have been any significant changes to the capital loss carryover numbers included in the “The Transaction—Federal Income Tax Considerations” section since December 31, 2024.

Comment 10. In the “Summary—Who bears the expenses associated with the Reorganization?” section, please clarify in the disclosure if the brokerage/transaction costs for portfolio transactions referenced in the section are the costs associated with repositioning described in the “Summary—Is the Reorganization considered a taxable event for federal income tax purposes?” section. If not, please also clarify in the disclosure that in addition to repositioning costs, the Acquired Portfolio will bear these additional costs as well.

1. It appears that the tax opinion filed as Exhibit 8.1 to the registration statement is a short-form opinion. If true, please revise your disclosure in this section to clearly identify each material tax consequence being opined upon, set forth the opinion as to each identified tax item, and set forth the basis for the opinion, stating clearly that the disclosure is the opinion of the named counsel. Please also revise the tax opinion filed as Exhibit 8.1 to clarify that the statements relating to material United States Federal income tax consequences are the opinion of counsel rather than an "accurate summary." Finally, please revise this heading, the preceding heading, and the body of this section to remove the word "certain" from "certain material" income tax consequences. Refer to Section III.C of Staff Legal Bulletin No. 19 (CF).

Comment 21 – United States Federal Income Tax Consequences – Taxation of the Trust, page 53 Please reconcile the disclosure that “[a]ssuming that the Trust is currently a grantor trust for U.S. federal income tax purposes” with the remainder of the discussion in this section.

3. We note your reconciliation between core adjusted operating income and the comparable GAAP measure on slides 22 and 23 in the 1Q25 Prudential Financial, Inc. Earnings Conference Call Presentation included in the Investor Relations section of your web-site. ● Please provide us a description of each adjustment after adjusted operating income before income taxes to get to core adjusted operating income before taxes clearly describing the nature of and reasons for the components being backed out and/or added in to allow us to fully understand why the resulting measure is useful for management and investors. Specifically quantify the amounts included/excluded to get to average expectations of alternative investment income, underwriting income and expected expenses and other items. ● Please tell us how you considered whether core adjusted operating income and related measures substitute…