Correspondence 0000035315-25-000832 from FIDELITY SALEM STREET TRUST (CIK 0000035315)
FIDELITY SALEM STREET TRUST (CIK 0000035315)
Date: Sept. 29, 2025 · CIK: 0000035315 · Accession: 0000035315-25-000832
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-02105
Letter
Converted by EDGARwiz COMMENTS RECEIVED ON 09/17/2025 FROM DANIEL GREENSPAN FIDELITY SALEM STREET TRUST (File Nos. 002-41839 and 811-02105) Fidelity SAI 0-5 Year Inflation-Protected Bond Index Fund Fidelity SAI Emerging Markets Momentum Index Fund POST-EFFECTIVE AMENDMENT NO. 602 1) All funds “Fund Summary” (prospectus) “Principal Investment Strategies” C: The Staff requests we expand to disclose the number or range of index components for the underlying index, as well as the rebalancing and reconstitution process. R: For Fidelity SAI 0-5 Year Inflation-Protected Bond Index Fund, we are not aware of a requirement to disclose the number of index components or the rebalance and reconstitution process of a third-party index. We believe the description provided for the fund’s third-party index, as provided in the “Investment Details” section, is sufficient. Accordingly, we have not modified disclosure. For Fidelity SAI Emerging Markets Momentum Index Fund, Fidelity ’ s rules ‐ based proprietary index methodology for the fund is described in plain English in the “ Fund Basics ” section under “ Principal Investment Strategies. ” In addition, the “ Appendix ” section of the prospectus will note that “ [a]dditional information regarding the index or indices is available on i.fidelity.com/indices.” This website contains the complete index methodology, which includes starting universe and other information. Accordingly, we do not believe additional disclosure is needed. 2) Fidelity SAI 0-5 Year Inflation-Protected Bond Index Fund “Fund Summary” (prospectus) “Principal Investment Strategies” C: The Staff requests we explain the concept of duration and provide an example of how it works. R: The fund does not have a principal investment strategy of investing in securities of issuers with a particular duration. The fund does have a principal investment strategy of normally investing 80% of the fund’s assets in securities included in an index and the index description included in the fund’s prospectus includes the disclosure excerpted below: “The Bloomberg US Treasury Inflation-Protected Securities (TIPS) 0-5 Years Index is a value-weighted index that measures the performance of inflation-protected securities issued by the U.S. Treasury that have a remaining average life of less than 5 years.” Accordingly, we have not modified the disclosure. 3) Fidelity SAI Emerging Markets Momentum Index Fund “Fund Summary” (prospectus) “Principal Investment Strategies” C: Given that the capitalization at the lower end of the index would be $100 million the Staff requests we explain how that is consistent with an index that tracks mid-cap companies. R: The fund does not have a principal investment strategy of investing in “mid-cap companies”. The fund invests 80% of its assets in “securities of companies included in the Fidelity Emerging Markets Momentum Focus Index”. In addition, the fund provides a description of that index, which includes “stocks of large- and -mid-capitalization companies”. As such, we believe the disclosure clearly identifies the principal investment strategies of the fund.
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CORRESP 1 filename1.htm Converted by EDGARwiz COMMENTS RECEIVED ON 09/17/2025 FROM DANIEL GREENSPAN FIDELITY SALEM STREET TRUST (File Nos. 002-41839 and 811-02105) Fidelity SAI 0-5 Year Inflation-Protected Bond Index Fund Fidelity SAI Emerging Markets Momentum Index Fund POST-EFFECTIVE AMENDMENT NO. 602 1) All funds “Fund Summary” (prospectus) “Principal Investment Strategies” C: The Staff requests we expand to disclose the number or range of index components for the underlying index, as well as the rebalancing and reconstitution process. R: For Fidelity SAI 0-5 Year Inflation-Protected Bond Index Fund, we are not aware of a requirement to disclose the number of index components or the rebalance and reconstitution process of a third-party index. We believe the description provided for the fund’s third-party index, as provided in the “Investment Details” section, is sufficient. Accordingly, we have not modified disclosure. For Fidelity SAI Emerging Markets Momentum Index Fund, Fidelity ’ s rules ‐ based proprietary index methodology for the fund is described in plain English in the “ Fund Basics ” section under “ Principal Investment Strategies. ” In addition, the “ Appendix ” section of the prospectus will note that “ [a]dditional information regarding the index or indices is available on i.fidelity.com/indices.” This website contains the complete index methodology, which includes starting universe and other information. Accordingly, we do not believe additional disclosure is needed. 2) Fidelity SAI 0-5 Year Inflation-Protected Bond Index Fund “Fund Summary” (prospectus) “Principal Investment Strategies” C: The Staff requests we explain the concept of duration and provide an example of how it works. R: The fund does not have a principal investment strategy of investing in securities of issuers with a particular duration. The fund does have a principal investment strategy of normally investing 80% of the fund’s assets in securities included in an index and the index description included in the fund’s prospectus includes the disclosure excerpted below: “The Bloomberg US Treasury Inflation-Protected Securities (TIPS) 0-5 Years Index is a value-weighted index that measures the performance of inflation-protected securities issued by the U.S. Treasury that have a remaining average life of less than 5 years.” Accordingly, we have not modified the disclosure. 3) Fidelity SAI Emerging Markets Momentum Index Fund “Fund Summary” (prospectus) “Principal Investment Strategies” C: Given that the capitalization at the lower end of the index would be $100 million the Staff requests we explain how that is consistent with an index that tracks mid-cap companies. R: The fund does not have a principal investment strategy of investing in “mid-cap companies”. The fund invests 80% of its assets in “securities of companies included in the Fidelity Emerging Markets Momentum Focus Index”. In addition, the fund provides a description of that index, which includes “stocks of large- and -mid-capitalization companies”. As such, we believe the disclosure clearly identifies the principal investment strategies of the fund.