Certificate of Accounting of Securities and Similar
Investments in the Custody of
Management Investment Companies
Pursuant to Rule 17f-2 [17 CFR 270.17f-2]
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1. Investment Company Act File Number:
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Date examination completed:
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811-08839
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June 30, 2019
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2. State Identification Number:
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AL
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AK
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AZ
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AR
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CA
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CO
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CT
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DE
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DC
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FL
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GA
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HI
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ID
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IL
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IN
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IA
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KS
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KY
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LA
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ME
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MD
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MA
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MI
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MN
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MS
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MO
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MT
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NE
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NV
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NH
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NJ
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NM
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NY
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NC
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ND
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OH
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OK
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OR
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PA
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RI
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SC
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SD
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TN
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TX
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UT
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VT
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VA
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WA
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WV
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WI
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WY
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PUERTO RICO
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Other (specify):
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3. Exact name of investment company as specified in registration statement:
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SPDR Series Trust
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4. Address of principal executive office: (number, street, city, state, zip code)
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One Iron Street, Boston, MA 02210
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Ernst & Young LLP
200 Clarendon Street
Boston, MA 02116
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Tel: +1 617 266 2000
Fax: +1 617 266 5843
ey.com
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Report of Independent Registered Public Accounting Firm
To the Board of Trustees of
SPDR Series Trust
We have examined managements assertion, included in the accompanying Management Statement Regarding Compliance With Certain Provisions of the Investment
Company Act of 1940, that SPDR Series Trust (the Trust) complied with the requirements of subsections (b) and (c) of rule 17f-2 under the Investment Company Act of 1940 (the Act) as of June 30, 2019. Management is responsible
for the Trusts compliance with those requirements. Our responsibility is to express an opinion on managements assertion about the Trusts compliance based on our examination.
Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included
examining, on a test basis, evidence about the Trusts compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. Included among our procedures were the following tests performed as
of June 30, 2019 and with respect to agreement of security purchases and sales, for the period from December 31, 2018 (the date of our last examination) through June 30, 2019:
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Confirmation of all securities in book entry form held by the Depository Trust Company, Federal Reserve Bank and
International Depositories;
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Confirmation of all securities hypothecated, pledged, placed in escrow or out for transfer with brokers, pledgees
or transfer agents;
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Reconciliation of all securities between the books and records of the Trust and the Custodian;
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Review of the reconciliation procedures performed by the Custodian at an omnibus level between the Depository
Trust Company, Federal Reserve Bank and International Depositories and the books and records of the Custodian; and
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Agreement of one security purchase and one security sale, for each Fund in the Trust, since our last report from
the books and records of the Trust to purchase and sales reports from the Trusts administrator.
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We believe that our examination
provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Trusts compliance with specified requirements.
In our opinion, managements assertion that SPDR Series Trust complied with the requirements of subsections
(b) and (c) of rule 17f-2 of the Act as of June 30, 2019, with respect to securities reflected in the investment account of the Trust is fairly stated, in all material respects.
This report is intended solely for the information and use of management and the Board of Trustees of SPDR Series Trust and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone other than these specified parties.
/s/ Ernst & Young
LLP
Boston, Massachusetts
January 31, 2020
Management Statement Regarding Compliance with Certain Provisions of the
Investment Company Act of 1940
January 31, 2020
We, as members of management of SPDR Series Trust (the Trust), are responsible for complying with the requirements of subsections (b) and (c)
of rule 17f-2, Custody of Investments by Registered Management Investment Companies, of the Investment Company Act of 1940 (the Act). We are also responsible for establishing and maintaining effective internal controls over
compliance with those requirements. We have performed an evaluation of the Funds compliance with the requirements of subsections (b) and (c) of rule 17f-2 as of June 30, 2019, and from December 31, 2018 through June 30, 2019.
Based on this evaluation, we assert that the Trust was in compliance with the requirements of subsections (b) and (c) of rule 17f-2 of the Act as of June 30,
2019, and from December 31, 2018 through June 30, 2019, with respect to securities reflected in the investment account of the Funds.
SPDR Series Trust
By:
/s/ Bruce Rosenberg
Bruce S. Rosenberg
Treasurer
SPDR S&P Internet ETF (AMEX:XWEB)
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