SEC Company Response from Eaton Vance Growth Trust (CIK 0000102816) — Dec 18, 2025
Eaton Vance Growth Trust (CIK 0000102816)
Date: Dec. 18, 2025 · CIK: 0000102816 · Accession: 0001133228-25-013567
AI Filing Summary & Sentiment
File numbers found in text: 811-01241
Letter
Division of Investment Management 100 F Street, NE Washington, DC 20549 Attn: Ashley Vroman-Lee Re: Eaton Vance Growth Trust (File No. 811-01241) (the “Registrant”)
Dear Ms. Vroman-Lee:
This letter responds to a comment provided on December 5, 2025, by the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) with respect to Post-Effective Amendment No. 233 (the “Amendment”) to the Registrant’s registration statement on Form N-1A (the “Registration Statement”) relating to Eaton Vance All Asset Strategy Fund and Eaton Vance Equity Strategy Fund, each a series of the Registrant (together, the “Funds”). The Amendment was filed with the SEC, via the EDGAR system, pursuant to Rule 485(a) under the Securities Act of 1933, as amended, on October 30, 2025 for the purpose of updating the Funds’ disclosure in compliance with annual updating requirements.
The Staff’s comment is summarized below, followed by the Registrant’s response. Capitalized terms not otherwise defined herein have the meanings set forth in the Amendment.
* * *
1. Comment: Please include frontier markets risk disclosure as is disclosed in the principal investment strategy section (“PIS”). Please apply globally, where applicable.
Response: The Registrant respectfully notes that the Emerging Markets Investments risk factor in each Fund’s summary prospectus and prospectus discloses risks associated with investments in frontier markets. However, in response to the Staff’s comment and to further disclose the risks associated with investments in frontier markets, the Registrant has added a separate Frontier Market Investments risk factor to the summary prospectus and prospectus for each Fund.
* * *
We hope the foregoing response adequately addresses the Staff’s comment. Should you have any further questions or comments, please do not hesitate to contact me at (617) 951-7499.
Sincerely,
/s/ Olivia R. Lanagan
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CORRESP
1
filename1.htm
ROPES
& GRAY LLP
PRUDENTIAL
TOWER
800
BOYLSTON STREET
BOSTON,
MA 02199-3600
WWW.ROPESGRAY.COM
Olivia
R. Lanagan
T
+1 617 951 7499
olivia.lanagan@ropesgray.com
December 18, 2025
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review Office
100 F Street, NE
Washington, DC 20549
Attn: Ashley Vroman-Lee
Re: Eaton Vance Growth Trust (File No. 811-01241) (the “Registrant”)
Dear Ms. Vroman-Lee:
This letter responds to a comment provided
on December 5, 2025, by the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) with
respect to Post-Effective Amendment No. 233 (the “Amendment”) to the Registrant’s registration statement on Form N-1A
(the “Registration Statement”) relating to Eaton Vance All Asset Strategy Fund and Eaton Vance Equity Strategy Fund, each
a series of the Registrant (together, the “Funds”). The Amendment was filed with the SEC, via the EDGAR system, pursuant to
Rule 485(a) under the Securities Act of 1933, as amended, on October 30, 2025 for the purpose of updating the Funds’ disclosure
in compliance with annual updating requirements.
The Staff’s comment is summarized below, followed by the Registrant’s
response. Capitalized terms not otherwise defined herein have the meanings set forth in the Amendment.
* * *
1. Comment: Please include frontier markets risk disclosure
as is disclosed in the principal investment strategy section (“PIS”). Please apply globally, where applicable.
Response: The Registrant respectfully
notes that the Emerging Markets Investments risk factor in each Fund’s summary prospectus and prospectus discloses risks associated
with investments in frontier markets. However, in response to the Staff’s comment and to further disclose the risks associated with
investments in frontier markets, the Registrant has added a separate Frontier Market Investments risk factor to the summary prospectus
and prospectus for each Fund.
* * *
We hope the foregoing response adequately addresses
the Staff’s comment. Should you have any further questions or comments, please do not hesitate to contact me at (617) 951-7499.
Sincerely,
/s/ Olivia R. Lanagan
cc: Nicholas Di Lorenzo, Morgan Stanley Investment Management
Sarah Clinton, Ropes & Gray LLP
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