SEC Company Response from FIDELITY SALEM STREET TRUST (CIK 0000035315) — Dec 11, 2025
FIDELITY SALEM STREET TRUST (CIK 0000035315)
Date: Dec. 11, 2025 · CIK: 0000035315 · Accession: 0000035315-25-001185
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-02105
Letter
Converted by EDGARwiz
COMMENTS RECEIVED ON 12/10/2025
FROM KIM McMANUS
FIDELITY SALEM STREET TRUST (File Nos. 002-41839 and 811-02105)
Fidelity Flex International Index Fund
POST-EFFECTIVE AMENDMENT NO. 605
“Investment Details” (prospectus)
“Principal Investment Strategies”
“The Fidelity Global ex U.S. IndexSM is a float-adjusted market capitalization-weighted index designed to reflect the performance of stocks of non-U.S. large- and mid-capitalization companies.
The Fidelity Global ex U.S. IndexSM was created by FPS using a rules-based proprietary index methodology that includes all non-U.S. large- and mid-capitalization stocks meeting certain market capitalization, liquidity, and investability requirements. The index is rebalanced annually, with a provision to make adjustments for certain corporate actions on a quarterly basis. FPS is the index provider. FPS is an affiliated person of the Adviser.”
C:
The Staff requests we expand the principal investment strategies discussion to describe the liquidity and investability requirements that are part of the index methodology.
R:
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 fund’s prospectus notes that “[a]dditional information regarding the
index or indices is available on i.fidelity.com/indices.” This website contains the complete index methodology. Accordingly, we do not believe additional disclosure is needed.
Show Raw Text
CORRESP 1 filename1.htm Converted by EDGARwiz COMMENTS RECEIVED ON 12/10/2025 FROM KIM McMANUS FIDELITY SALEM STREET TRUST (File Nos. 002-41839 and 811-02105) Fidelity Flex International Index Fund POST-EFFECTIVE AMENDMENT NO. 605 “Investment Details” (prospectus) “Principal Investment Strategies” “The Fidelity Global ex U.S. IndexSM is a float-adjusted market capitalization-weighted index designed to reflect the performance of stocks of non-U.S. large- and mid-capitalization companies. The Fidelity Global ex U.S. IndexSM was created by FPS using a rules-based proprietary index methodology that includes all non-U.S. large- and mid-capitalization stocks meeting certain market capitalization, liquidity, and investability requirements. The index is rebalanced annually, with a provision to make adjustments for certain corporate actions on a quarterly basis. FPS is the index provider. FPS is an affiliated person of the Adviser.” C: The Staff requests we expand the principal investment strategies discussion to describe the liquidity and investability requirements that are part of the index methodology. R: 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 fund’s prospectus notes that “[a]dditional information regarding the index or indices is available on i.fidelity.com/indices.” This website contains the complete index methodology. Accordingly, we do not believe additional disclosure is needed.