Correspondence 0001193125-24-073552 from COLUMBIA ACORN TRUST (CIK 0000002110)
COLUMBIA ACORN TRUST (CIK 0000002110)
Date: March 21, 2024 · CIK: 0000002110 · Accession: 0001193125-24-073552
AI Filing Summary & Sentiment
File numbers found in text: 333-131683, 333-89661, 811-01829, 811-04367, 811-09645, 811-21852
Letter
Division of Investment Management, Disclosure Review Office Columbia Funds Series Trust Columbia Funds Series Trust I Columbia Funds Series Trust II (each, a Registrant and together, the Registrants)
Re: Template Filing Relief Request Pursuant to Rule 485(b)(1)(vii) for
Dear Mr. Cowan:
On December 8, 2023, pursuant to Rule 485(a)(1), we filed with the Commission Post-Effective Amendment No. 410 to the Registration Statement under the Securities Act of 1933, as amended (the “1933 Act”), and Amendment No. 414 to the Registration Statement under the Investment Company Act of 1940 (the “1940 Act”) of Columbia Funds Series Trust I (File Nos. 2-99356 and 811-04367), on behalf of its series, Columbia Real Estate Equity Fund (the “Template Filing”). The Template Filing was filed in order to register one new class of shares, Class S shares, to be offered by Columbia Real Estate Equity Fund.
The Registrants, on behalf of the funds listed in Exhibit A (the “Replicate Funds”), intend to offer Class S shares to the investing public pursuant to prospectuses that are expected to be effective on or before October 1, 2024 (the “Effective Date”). Normally, this would require each Registrant to file an amended registration statement under Rule 485(a)(1) with respect to each impacted series fund. However, because the disclosure pertaining to the new share class for all impacted series funds will be identical to the corresponding disclosure in the Template Filing, we respectfully request permission to file a registration statement (the “Replicate Filing”) for each of the Replicate Funds pursuant to Rule 485(b)(1)(vii) under the 1933 Act on or before October 1, 2024. Any disclosure changes resulting from the staff’s review of the Template Filing related to Class S shares, will be incorporated into the Replicate Filings, as applicable. We note that the registration statements of the Registrants were last reviewed as set forth in the following table:
Registrant
1933 Act #
1940 Act #
Most Recent 485(a)(1) filing
Columbia Acorn Trust
002-34223
811-01829
2/28/2018
Columbia Funds Series Trust
333-89661
811-09645
6/29/2022
Columbia Funds Series Trust I
002-99356
811-04367
12/8/2023
Columbia Funds Series Trust II
333-131683
811-21852
10/19/2022
In support of this request, the Registrants, on behalf of each of the Replicate Funds, make the following representations:
•
The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the Replicate Filings.
•
The Replicate Filings incorporate changes made to the disclosure included in the Template Filing to resolve any staff comments thereon.
•
The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b) under the 1933 Act.
If you have any questions, please contact either me at 212-850-1703 or Anna Butskaya at 612-671-4993.
Sincerely,
/s/ Joseph D’Alessandro
Show Raw Text
CORRESP 1 filename1.htm CORRESP March 21, 2024 Mr. Mark Cowan U.S. Securities and Exchange Commission Division of Investment Management, Disclosure Review Office 100 F Street, N.E. Washington, D.C. 20549 Re: Template Filing Relief Request Pursuant to Rule 485(b)(1)(vii) for Columbia Acorn Trust Columbia Funds Series Trust Columbia Funds Series Trust I Columbia Funds Series Trust II (each, a Registrant and together, the Registrants) Dear Mr. Cowan: On December 8, 2023, pursuant to Rule 485(a)(1), we filed with the Commission Post-Effective Amendment No. 410 to the Registration Statement under the Securities Act of 1933, as amended (the “1933 Act”), and Amendment No. 414 to the Registration Statement under the Investment Company Act of 1940 (the “1940 Act”) of Columbia Funds Series Trust I (File Nos. 2-99356 and 811-04367), on behalf of its series, Columbia Real Estate Equity Fund (the “Template Filing”). The Template Filing was filed in order to register one new class of shares, Class S shares, to be offered by Columbia Real Estate Equity Fund. The Registrants, on behalf of the funds listed in Exhibit A (the “Replicate Funds”), intend to offer Class S shares to the investing public pursuant to prospectuses that are expected to be effective on or before October 1, 2024 (the “Effective Date”). Normally, this would require each Registrant to file an amended registration statement under Rule 485(a)(1) with respect to each impacted series fund. However, because the disclosure pertaining to the new share class for all impacted series funds will be identical to the corresponding disclosure in the Template Filing, we respectfully request permission to file a registration statement (the “Replicate Filing”) for each of the Replicate Funds pursuant to Rule 485(b)(1)(vii) under the 1933 Act on or before October 1, 2024. Any disclosure changes resulting from the staff’s review of the Template Filing related to Class S shares, will be incorporated into the Replicate Filings, as applicable. We note that the registration statements of the Registrants were last reviewed as set forth in the following table: Registrant 1933 Act # 1940 Act # Most Recent 485(a)(1) filing Columbia Acorn Trust 002-34223 811-01829 2/28/2018 Columbia Funds Series Trust 333-89661 811-09645 6/29/2022 Columbia Funds Series Trust I 002-99356 811-04367 12/8/2023 Columbia Funds Series Trust II 333-131683 811-21852 10/19/2022 In support of this request, the Registrants, on behalf of each of the Replicate Funds, make the following representations: • The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the Replicate Filings. • The Replicate Filings incorporate changes made to the disclosure included in the Template Filing to resolve any staff comments thereon. • The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b) under the 1933 Act. If you have any questions, please contact either me at 212-850-1703 or Anna Butskaya at 612-671-4993. Sincerely, /s/ Joseph D’Alessandro Joseph D’Alessandro Vice President and Group Counsel Ameriprise Financial, Inc. EXHIBIT A Columbia Acorn Trust Columbia Acorn Fund Columbia Acorn International Columbia Acorn International Select Columbia Thermostat Fund Columbia Funds Series Trust Columbia California Intermediate Municipal Bond Fund Columbia Capital Allocation Moderate Aggressive Portfolio Columbia Convertible Securities Fund Columbia Large Cap Enhanced Core Fund Columbia Large Cap Growth Opportunity Fund Columbia Overseas Value Fund Columbia Select Large Cap Equity Fund Columbia Select Mid Cap Value Fund Columbia Short Duration Municipal Bond Fund Columbia Short Term Bond Fund Columbia Small Cap Value Fund II Columbia Funds Series Trust I Columbia Adaptive Risk Allocation Fund Columbia Balanced Fund Columbia Bond Fund Columbia Contrarian Core Fund Columbia Corporate Income Fund Columbia Dividend Income Fund Columbia Emerging Markets Fund Columbia Global Technology Growth Fund Columbia High Yield Municipal Fund Columbia Intermediate Duration Municipal Bond Fund Columbia International Dividend Income Fund Columbia Large Cap Growth Fund Columbia Oregon Intermediate Municipal Bond Fund Columbia Select Large Cap Growth Fund Columbia Select Mid Cap Growth Fund Columbia Small Cap Growth Fund Columbia Small Cap Value Fund I Columbia Strategic Income Fund Columbia Tax-Exempt Fund Columbia Total Return Bond Fund Columbia Funds Series Trust II Columbia Dividend Opportunity Fund Columbia Flexible Capital Income Fund Columbia Floating Rate Fund Columbia Global Value Fund Columbia High Yield Bond Fund Columbia Income Opportunities Fund Columbia Mortgage Opportunities Fund Columbia Select Large Cap Value Fund Columbia Seligman Global Technology Fund Columbia Seligman Technology and Information Fund Columbia Strategic Municipal Income Fund