I’m assuming that you are not the adviser to the ETF’s, but rather that you’ve chosen a group of common ETF’s for blanket pre-clearance.  Unless the fund you sub-advise is trading in those ETF’s then the black-out period would not generally apply.  The blackout is intended to prevent actual or apparent conflicts of interest with investment personnel’s personal trading and the trading of the mutual fund. Nevertheless, advisers should consider closely reviewing employee transactions in securities purchased for clients under both 17j-1 and 204A-1 for conflicting trading such as front-running.