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Correspondence 0001193125-23-290790 from JOHN HANCOCK INVESTMENT TRUST (CIK 0000022370)

JOHN HANCOCK INVESTMENT TRUST (CIK 0000022370)
Date: Dec. 7, 2023 · CIK: 0000022370 · Accession: 0001193125-23-290790

AI Filing Summary & Sentiment

File numbers found in text: 811-00560

Date
December 7, 2023
Author
Not clearly detected
Form
CORRESP
Company
JOHN HANCOCK INVESTMENT TRUST (CIK 0000022370)

Letter

VIA EDGAR Division of Investment Management Washington, D.C. 02549 Attention: Sonny Oh Re: John Hancock Investment Trust (the “Trust”) — File No. 002-10156; 811-00560 Registration Statement on Form N-1A

Dear Mr. Oh:

On behalf of the Trust, we submit this letter in response to comments received by telephone on November 15, 2023, from the staff (“Staff”) of the Securities and Exchange Commission (the “SEC”) with respect to Post-effective Amendment No. 223 under the Securities Act of 1933, as amended, and Amendment No. 175 under the Investment Company Act of 1940, as amended (the “1940 Act”), to the Trust’s Registration Statement on Form N-1A, filed with the SEC on October 4, 2023, accession no. 0001193125-23-250794 (the “Amendment”). The Amendment relates to John Hancock Global Climate Action Fund, a series of the Trust (the “Fund”).

For convenience, we have set forth each comment below, followed by the Trust’s response. Unless otherwise stated, capitalized terms have the same meaning as given in the Amendment.

Prospectus Comments

Comment 1 — Please include the exchange ticker symbol for each class of shares of the Fund on the front cover of the prospectus and the Statement of Additional Information (the “SAI”).

Response to Comment 1 — The exchange ticker symbol of each class of shares of the Fund will be included on the front cover of the prospectus and the SAI when such class of shares is offered to the general public.

Comment 2 — The SEC Staff notes that there are certain bracketed or omitted items in the Amendment. Please finalize and complete any omitted information in the Fund’s final filing. Please also provide for the Staff’s review completed fee tables under “Fund summary – Fees and expenses” as part of this letter.

K&L GATES LLP

STATE STREET FINANCIAL CENTER ONE LINCOLN STREET BOSTON MA 02111

T +1 617 261 3231 F +1 617 261 3175 klgates.com

Response to Comment 2 — The Trust confirms it will make the requested changes and will finalize and include any omitted information in the final filing. Additionally, the fee tables for the Fund and the share class described in the Amendment are included in Appendix A to this letter.

Comment 3 — With respect to the name of the Fund, the SEC Staff feels that the term “Climate Action” is a word that denotes a type of investment and that the Fund, therefore, should include an 80% investment policy, as required by Rule 35d-1 under the 1940 Act (the “Names Rule”).

Response to Comment 3 — While the Trust respectfully disagrees that the Fund’s name is subject to the requirements of the Names Rule, in response to the Staff’s comment, the Trust will revise the disclosure under the heading “Fund summary – Principal investment strategies” to include the following 80% investment policy:

Under normal market conditions, the fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in equity securities including, but not limited to, common stocks and depositary receipts of issuers that the manager determines are Climate Leaders (as defined below), which are listed on any exchange across the globe (inclusive of the emerging markets).

Comment 4 — With respect to the Fund’s investment objective, the SEC Staff notes that the objective of “capital growth” is subordinate to “environmental, social or governance” (ESG) or climate considerations. Please consider whether ESG or “climate” should be incorporated into the Fund’s investment objective. If the Trust believes they should not incorporated, please explain in your response why it should not be incorporated, given the Fund’s principal investment strategies.

Response to Comment 4 — The Trust respectfully notes that it does not believe the Fund’s investment objective of capital growth is “subordinate to” ESG or climate considerations and respectfully disagrees with that characterization. Nevertheless, in response to the Staff’s comment, the Trust will revise the investment objective to read as follows:

“The fund seeks to provide long-term capital growth by investing in a diversified portfolio of Climate Leaders (as defined below).”

Comment 5 — Under “Fund Summary — Fees and expenses,” in the “Shareholder fees” table, please move the parenthetical disclosure regarding the Class A maximum deferred sales charge to a footnote.

Response to Comment 5 — The Trust believes that the placement of this disclosure is appropriate. Accordingly, the Trust respectfully declines to make any changes in response to this comment.

Comment 6 — Under “Fund Summary — Fees and expenses,” in the “Annual fund operating expenses” table, the SEC Staff notes that there are variances between the total expenses of each share class. Please supplementally explain these variance.

Response to Comment 6 — Supplementally, the Trust notes that the total expenses for the share classes differ because of the Rule 12b-1 fees that are paid by each class and differences in transfer agency fees paid by each class.

Comment 7 — Under “Fund Summary — Fees and expenses,” in the “Annual fund operating expenses” table, please confirm that the duration of both contractual waivers will be in effect for at least a one-year period from the date of effectiveness of the registration statement. Please also disclose, if applicable, whether the adviser may recoup expenses, and if so, disclose the time period and that recoupment may only occur if it does not result in an expense ratio that exceeds the expense cap in place at the time of both the waiver and recoupment.

Response to Comment 7 — The Registrant confirms that any contractual waivers will be in effect for at least one year from the date of effectiveness, and further notes that waived or reimbursed expenses are not subject to recoupment by the adviser.

Comment 8 — Under “Fund summary – Principal investment strategies,” please disclose how the Fund defines “emerging markets.”

Response to Comment 8 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 9 — Under “Fund summary – Principal investment strategies,” please clarify the interplay between the exclusionary screen relating to the Ten Principles of the United Nations Global Compact (the “Ten Principles”) and the sentence that states that the screen “includes issuers with products or within industries that are considered by the exclusionary screen to be unsustainable or associated with significant environmental or social risks.”

Response to Comment 9 — Supplementally, the Trust notes that the screen that excludes “issuers with products or within industries that are considered by third-party data provider(s) to be unsustainable or associated with significant environmental or social risks” is applied in addition to the Ten Principles exclusionary screen. In response to the Staff’s comment, however, the Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 10 — Under “Fund summary – Principal investment strategies,” please identify the provider or providers the Fund intends to use to apply the exclusionary screen. Please describe the criteria or methodology used by each provider when applying the exclusionary framework. In doing so, the Fund should describe its due diligence practice in applying the screening criteria to portfolio companies, what underlying data will be reviewed to determine whether a company will be excluded and the sources of that data. If applicable, also consider any related principal risks related to the Fund’s use of third party data providers since the data used by providers can differ significantly.

Response to Comment 10 — In response to the Staff’s comment, the Trust supplementally notes that it believes the current disclosure is adequate and consistent with the requirements of Form N-1A. First, while the manager will use third-party data providers to screen out ineligible investments, the manager ultimately relies on its own fundamental analysis to select securities for the Fund’s

portfolio, as described in the Fund’s principal investment strategies. Therefore, the Trust believes that naming specific third-party data providers overemphasizes their importance in the investment process. The Trust further notes that such data providers may change over time.

Second, the Trust notes that the exclusionary framework may be updated from time to time and, as the information by the third-party data provider does not constitute investment advice but rather a set of data that is used by the manager, the Trust does not believe that additional description of the criteria and methodology used by the third-party service provider is necessary. In this regard, the Trust further notes that, consistent with Item 9(b)(2) of Form N-1A the Trust believes that the principal investment strategies generally explain how the manager chooses securities, including a general description of the exclusionary framework.

Accordingly, the Trust respectfully declines to make any changes to the Principal investment strategies in response to this comment. However, the Trust will revise the principal risk disclosure to disclose the risk that information and data provided by third parties may be inaccurate and/or incomplete.

Comment 11 — Under “Fund summary – Principal investment strategies,” please more clearly explain the Ten Principles. For example, please describe each of the Ten Principles and clarify if the Fund will focus on any specific principle or it will focus on all of the Ten Principles.

Response to Comment 11 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 12 — Under “Fund summary – Principal investment strategies,” in the second paragraph, please clarify that the disclosure refers to the manager’s exclusionary screen, if applicable.

Response to Comment 12 — In response to this comment, the Trust respectfully refers to the Staff its responses to Comments 9 and 11.

Comment 13 — Under “Fund summary – Principal investment strategies,” the disclosure states: “Subject to the fund’s selection process as described herein, issuers deriving up to 25% of revenue from fossil fuel-based power generation may be included in the fund’s portfolio if those issuers have adopted an aggressive decarbonization pathway and/or are growing their renewable energy portfolios.” Please clarify in the disclosure what is meant by “adopting an aggressive decarbonization pathway” and “growing their renewable energy portfolios.”

Response to Comment 13 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 14 — Under “Fund summary – Principal investment strategies,” the disclosure states: “Where no data is available from the third-party data provider(s) regarding compliance with the exclusionary framework above, issuers will not be excluded from the fund’s investment universe provided that they satisfy the positive screen applied by the manager” (emphasis added). Please clarify what is meant by “positive screen.” For example, is this a screen that is used in addition to the exclusionary screen?

Response to Comment 14 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 15 — Under “Fund summary – Principal investment strategies,” the disclosure states: “In selecting issuers that are climate leaders, the manager will consider issuers that have: (a) signified commitment to develop or have set science-based targets with the Science Based Targets initiative …” Please describe in more detail the “Science Based Targets initiative” and, in particular, how the “Science Based Targets initiatives” are connected to the Paris Agreement.

Response to Comment 15 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 16 — Under “Fund summary – Principal investment strategies,” with respect to the portion of the Fund’s strategy in which the manager selects securities from the universe of remaining potential investments after the application of the exclusionary screen, please identify the provider or the providers the Fund intends to use to select such securities, if applicable. Please describe the criteria or methodology used by each provider in connection with the same. In doing so, the Fund should describe its due diligence practice in applying the screening criteria to portfolio companies, what underlying data will be reviewed to determine whether a company will be excluded and the sources of that data. If applicable, also consider any related principal risks related to the Fund’s use of third-party data providers since the data used by providers can differ significantly.

Response to Comment 16 — Please see the Response to Comment 10.

Comment 17 — Under “Fund summary – Principal investment strategies,” the disclosure states: “The fund will also consider other sustainability and/or environmental, social, governance (“ESG”) attributes of issuers when choosing whether to invest, subject to data availability.” Please clarify whether climate or climate action is the exclusive factor considered by the Fund when selecting portfolio investments or whether it is one of several factors. If the latter, the disclosure should state that a portfolio investment could be made in a company that scores poorly on climate factors if it scores strongly on other, non-climate factors that are considered.

Response to Comment 17 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B:

Comment 18 — Under “Fund summary – Principal investment strategies,” please consider disclosing supplementally how many issuers the Fund expects to have in its portfolio.

Response to Comment 18 — The Trust notes supplementally that, under normal circumstances, the fund will invest in approximately 30-60 issuers.

Comment 19 — Under “Fund summary – Principal investment strategies,” the disclosure states: “An issuer’s eligibility status with respect to the relevant criteria in the fund’s security selection process at the time of investment may change over time.” Please clarify what is meant by “criteria.”

Response to Comment 19 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 20 — Under “Fund summary – Principal investment strategies,” the disclosure states: “Under normal circumstances, the fund will invest in companies domiciled, incorporated, organized or headquartered outside the U.S., including developing and emerging market countries (Foreign Companies).” Please reconcile that disclosure with similar disclosure in the first paragraph of the “Principal investment strategies” which refers to climate leaders which are listed on any exchange across the globe, inclusive of emerging markets. If the later disclosure is retained, please expressly describe how the Fund will invest its assets in investments that are tied economically to a number of countries throughout the world. Please see Footnote 42 to Investment Company Act Release No. 24828 (Jan. 17, 2001).

Response to Comment 20 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

Comment 21 — Under “Fund summary – Principal investment strategies,” please explain supplementally how companies “domiciled, incorporated or headquartered outside the U.S. satisfies the test described above in Comment 20 which requires that an investment is economically tied to a particular country.

Response to Comment 21 — The Trust notes supplementally that it has revised the noted disclosure and, therefore, a response to this comment is not necessary.

Show Raw Text
CORRESP
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filename1.htm

JOHN HANCOCK INVESTMENT TRUST

 December 7, 2023

VIA EDGAR

 Division of Investment Management

U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 02549

 Attention: Sonny Oh

Re:
 John Hancock Investment Trust (the “Trust”) — File
No. 002-10156; 811-00560

 Registration Statement on Form N-1A

 Dear Mr. Oh:

 On behalf of the
Trust, we submit this letter in response to comments received by telephone on November 15, 2023, from the staff (“Staff”) of the Securities and Exchange Commission (the “SEC”) with respect to Post-effective
Amendment No. 223 under the Securities Act of 1933, as amended, and Amendment No. 175 under the Investment Company Act of 1940, as amended (the “1940 Act”), to the Trust’s Registration Statement on Form N-1A, filed with the SEC on October 4, 2023, accession no. 0001193125-23-250794 (the “Amendment”). The Amendment
relates to John Hancock Global Climate Action Fund, a series of the Trust (the “Fund”).

 For convenience, we have set forth each comment
below, followed by the Trust’s response. Unless otherwise stated, capitalized terms have the same meaning as given in the Amendment.

Prospectus Comments

 Comment 1
— Please include the exchange ticker symbol for each class of shares of the Fund on the front cover of the prospectus and the Statement of Additional Information (the “SAI”).

Response to Comment 1 — The exchange ticker symbol of each class of shares of the Fund will be included on the front cover of the
prospectus and the SAI when such class of shares is offered to the general public.

 Comment 2 — The SEC Staff notes that there are certain
bracketed or omitted items in the Amendment. Please finalize and complete any omitted information in the Fund’s final filing. Please also provide for the Staff’s review completed fee tables under “Fund summary – Fees and
expenses” as part of this letter.

 K&L GATES LLP

STATE STREET FINANCIAL CENTER    ONE LINCOLN STREET    BOSTON    MA 02111

T +1 617 261 3231 F +1 617 261 3175 klgates.com

 Response to Comment 2 — The Trust confirms it will make the requested changes and
will finalize and include any omitted information in the final filing. Additionally, the fee tables for the Fund and the share class described in the Amendment are included in Appendix A to this letter.

Comment 3 — With respect to the name of the Fund, the SEC Staff feels that the term “Climate Action” is a word that denotes a
type of investment and that the Fund, therefore, should include an 80% investment policy, as required by Rule 35d-1 under the 1940 Act (the “Names Rule”).

Response to Comment 3 — While the Trust respectfully disagrees that the Fund’s name is subject to the requirements of the
Names Rule, in response to the Staff’s comment, the Trust will revise the disclosure under the heading “Fund summary – Principal investment strategies” to include the following 80% investment policy:

Under normal market conditions, the fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in equity
securities including, but not limited to, common stocks and depositary receipts of issuers that the manager determines are Climate Leaders (as defined below), which are listed on any exchange across the globe (inclusive of the emerging markets).

 Comment 4 — With respect to the Fund’s investment objective, the SEC Staff notes that the objective of “capital growth” is
subordinate to “environmental, social or governance” (ESG) or climate considerations. Please consider whether ESG or “climate” should be incorporated into the Fund’s investment objective. If the Trust believes they should
not incorporated, please explain in your response why it should not be incorporated, given the Fund’s principal investment strategies.

Response to Comment 4 — The Trust respectfully notes that it does not believe the Fund’s investment objective of capital
growth is “subordinate to” ESG or climate considerations and respectfully disagrees with that characterization. Nevertheless, in response to the Staff’s comment, the Trust will revise the investment objective to read as follows:

“The fund seeks to provide long-term capital growth by investing in a diversified portfolio of Climate Leaders (as defined below).”

 Comment 5 — Under “Fund Summary — Fees and expenses,” in the “Shareholder fees” table, please move the parenthetical
disclosure regarding the Class A maximum deferred sales charge to a footnote.

 Response to Comment 5 — The Trust believes
that the placement of this disclosure is appropriate. Accordingly, the Trust respectfully declines to make any changes in response to this comment.

Comment 6 — Under “Fund Summary — Fees and expenses,” in the “Annual fund operating expenses” table, the SEC Staff notes
that there are variances between the total expenses of each share class. Please supplementally explain these variance.

 2

 Response to Comment 6 — Supplementally, the Trust notes that the total expenses for
the share classes differ because of the Rule 12b-1 fees that are paid by each class and differences in transfer agency fees paid by each class.

Comment 7 — Under “Fund Summary — Fees and expenses,” in the “Annual fund operating expenses” table, please confirm that
the duration of both contractual waivers will be in effect for at least a one-year period from the date of effectiveness of the registration statement. Please also disclose, if applicable, whether the adviser
may recoup expenses, and if so, disclose the time period and that recoupment may only occur if it does not result in an expense ratio that exceeds the expense cap in place at the time of both the waiver and recoupment.

Response to Comment 7 — The Registrant confirms that any contractual waivers will be in effect for at least one year from the date
of effectiveness, and further notes that waived or reimbursed expenses are not subject to recoupment by the adviser.

 Comment 8 — Under
“Fund summary – Principal investment strategies,” please disclose how the Fund defines “emerging markets.”

Response to Comment 8 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B.

 Comment 9 — Under “Fund summary – Principal investment strategies,” please clarify the interplay between the exclusionary
screen relating to the Ten Principles of the United Nations Global Compact (the “Ten Principles”) and the sentence that states that the screen “includes issuers with products or within industries that are considered by the
exclusionary screen to be unsustainable or associated with significant environmental or social risks.”

 Response to Comment 9
— Supplementally, the Trust notes that the screen that excludes “issuers with products or within industries that are considered by third-party data provider(s) to be unsustainable or associated with significant environmental or
social risks” is applied in addition to the Ten Principles exclusionary screen. In response to the Staff’s comment, however, the Trust has clarified the disclosure in response to the Staff’s comment as set forth in
Appendix B.

 Comment 10 — Under “Fund summary – Principal investment strategies,” please identify the provider or providers the
Fund intends to use to apply the exclusionary screen. Please describe the criteria or methodology used by each provider when applying the exclusionary framework. In doing so, the Fund should describe its due diligence practice in applying the
screening criteria to portfolio companies, what underlying data will be reviewed to determine whether a company will be excluded and the sources of that data. If applicable, also consider any related principal risks related to the Fund’s use of
third party data providers since the data used by providers can differ significantly.

 Response to Comment 10 — In response to
the Staff’s comment, the Trust supplementally notes that it believes the current disclosure is adequate and consistent with the requirements of Form N-1A. First, while the manager will use third-party
data providers to screen out ineligible investments, the manager ultimately relies on its own fundamental analysis to select securities for the Fund’s

 3

portfolio, as described in the Fund’s principal investment strategies. Therefore, the Trust believes that naming specific third-party data providers overemphasizes their importance in the
investment process. The Trust further notes that such data providers may change over time.

 Second, the Trust notes that the exclusionary
framework may be updated from time to time and, as the information by the third-party data provider does not constitute investment advice but rather a set of data that is used by the manager, the Trust does not believe that additional description of
the criteria and methodology used by the third-party service provider is necessary. In this regard, the Trust further notes that, consistent with Item 9(b)(2) of Form N-1A the Trust believes that the principal
investment strategies generally explain how the manager chooses securities, including a general description of the exclusionary framework.

Accordingly, the Trust respectfully declines to make any changes to the Principal investment strategies in response to this comment. However,
the Trust will revise the principal risk disclosure to disclose the risk that information and data provided by third parties may be inaccurate and/or incomplete.

Comment 11 — Under “Fund summary – Principal investment strategies,” please more clearly explain the Ten Principles. For example,
please describe each of the Ten Principles and clarify if the Fund will focus on any specific principle or it will focus on all of the Ten Principles.

Response to Comment 11 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in
Appendix B.

 Comment 12 — Under “Fund summary – Principal investment strategies,” in the second paragraph, please clarify
that the disclosure refers to the manager’s exclusionary screen, if applicable.

 Response to Comment 12 — In response to
this comment, the Trust respectfully refers to the Staff its responses to Comments 9 and 11.

 Comment 13 — Under “Fund summary –
Principal investment strategies,” the disclosure states: “Subject to the fund’s selection process as described herein, issuers deriving up to 25% of revenue from fossil fuel-based power generation may be included in the
fund’s portfolio if those issuers have adopted an aggressive decarbonization pathway and/or are growing their renewable energy portfolios.” Please clarify in the disclosure what is meant by “adopting an aggressive decarbonization
pathway” and “growing their renewable energy portfolios.”

 Response to Comment 13 — The Trust has clarified the
disclosure in response to the Staff’s comment as set forth in Appendix B.

 Comment 14 — Under “Fund summary – Principal
investment strategies,” the disclosure states: “Where no data is available from the third-party data provider(s) regarding compliance with the exclusionary framework above, issuers will not be excluded from the fund’s investment
universe provided that they satisfy the positive screen applied by the manager” (emphasis added). Please clarify what is meant by “positive screen.” For example, is this a screen that is used in addition to the
exclusionary screen?

 4

 Response to Comment 14 — The Trust has clarified the disclosure in response to the
Staff’s comment as set forth in Appendix B.

 Comment 15 — Under “Fund summary – Principal investment strategies,” the
disclosure states: “In selecting issuers that are climate leaders, the manager will consider issuers that have: (a) signified commitment to develop or have set science-based targets with the Science Based Targets initiative
…” Please describe in more detail the “Science Based Targets initiative” and, in particular, how the “Science Based Targets initiatives” are connected to the Paris Agreement.

Response to Comment 15 — The Trust has clarified the disclosure in response to the Staff’s comment as set forth in
Appendix B.

 Comment 16 — Under “Fund summary – Principal investment strategies,” with respect to the portion of the
Fund’s strategy in which the manager selects securities from the universe of remaining potential investments after the application of the exclusionary screen, please identify the provider or the providers the Fund intends to use to select such
securities, if applicable. Please describe the criteria or methodology used by each provider in connection with the same. In doing so, the Fund should describe its due diligence practice in applying the screening criteria to portfolio companies,
what underlying data will be reviewed to determine whether a company will be excluded and the sources of that data. If applicable, also consider any related principal risks related to the Fund’s use of third-party data providers since the data
used by providers can differ significantly.

 Response to Comment 16 — Please see the Response to Comment 10.

Comment 17 — Under “Fund summary – Principal investment strategies,” the disclosure states: “The fund will also consider other
sustainability and/or environmental, social, governance (“ESG”) attributes of issuers when choosing whether to invest, subject to data availability.” Please clarify whether climate or climate action is the exclusive factor
considered by the Fund when selecting portfolio investments or whether it is one of several factors. If the latter, the disclosure should state that a portfolio investment could be made in a company that scores poorly on climate factors if it scores
strongly on other, non-climate factors that are considered.

 Response to Comment 17 —
The Trust has clarified the disclosure in response to the Staff’s comment as set forth in Appendix B:

 Comment 18 — Under “Fund
summary – Principal investment strategies,” please consider disclosing supplementally how many issuers the Fund expects to have in its portfolio.

Response to Comment 18 — The Trust notes supplementally that, under normal circumstances, the fund will invest in approximately 30-60 issuers.

 Comment 19 — Under “Fund summary – Principal investment strategies,” the
disclosure states: “An issuer’s eligibility status with respect to the relevant criteria in the fund’s security selection process at the time of investment may change over time.” Please clarify what is meant by
“criteria.”

 5

 Response to Comment 19 — The Trust has clarified the disclosure in response to the
Staff’s comment as set forth in Appendix B.

 Comment 20 — Under “Fund summary – Principal investment strategies,” the
disclosure states: “Under normal circumstances, the fund will invest in companies domiciled, incorporated, organized or headquartered outside the U.S., including developing and emerging market countries (Foreign Companies).” Please
reconcile that disclosure with similar disclosure in the first paragraph of the “Principal investment strategies” which refers to climate leaders which are listed on any exchange across the globe, inclusive of emerging markets. If the
later disclosure is retained, please expressly describe how the Fund will invest its assets in investments that are tied economically to a number of countries throughout the world. Please see Footnote 42 to Investment Company Act Release
No. 24828 (Jan. 17, 2001).

 Response to Comment 20 — The Trust has clarified the disclosure in response to the
Staff’s comment as set forth in Appendix B.

 Comment 21 — Under “Fund summary – Principal investment strategies,”
please explain supplementally how companies “domiciled, incorporated or headquartered outside the U.S. satisfies the test described above in Comment 20 which requires that an investment is economically tied to a particular country.

Response to Comment 21 — The Trust notes supplementally that it has revised the noted disclosure and, therefore, a response to this
comment is not necessary.