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Correspondence 0001104659-22-130201 from SEI DAILY INCOME TRUST /MA/ (CIK 0000701939)

SEI DAILY INCOME TRUST /MA/ (CIK 0000701939)
Date: Dec. 27, 2022 · CIK: 0000701939 · Accession: 0001104659-22-130201

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File numbers found in text: 811-03451

Date
December 9, 2022
Author
Jessica L. Accurso
Form
CORRESP
Company
SEI DAILY INCOME TRUST /MA/ (CIK 0000701939)

Letter

Division of Investment Management F Street, NE Washington, D.C. 20549 Re: Response letter to comments on Post-Effective Amendment No. 92 to the Registration Statement of SEI Daily Income Trust (File Nos. 002-77048 and 811-03451)

Dear Mr. Williams:

On behalf of our client, SEI Daily Income Trust (the “Trust” or “SDIT”), this letter responds to the comments and questions you provided via telephone on December 9, 2022, regarding the Trust’s Post-Effective Amendment No. 92, under the Securities Act of 1933, as amended (the “1933 Act”), and Amendment No. 91, under the Investment Company Act of 1940, as amended (the “1940 Act”), to its Registration Statement filed with the SEC on October 28, 2022 pursuant to Rule 485(a)(1) under the 1933 Act (the “Amendment”), for the purpose of introducing a new share class of the Government Fund (the “Fund”), a series of the Trust. As indicated in the Amendment, SEI Investments Management Corporation (“SIMC” or the “Adviser”) serves as investment adviser to the Fund. Below, we have briefly summarized your comments and questions, followed by our responses. Capitalized terms not defined herein should be given the meaning provided in the Amendment.

1. Comment. The Staff notes that when a comment is made in one location, it is applicable to all similar disclosure appearing elsewhere in the registration statement.

Response. Acknowledged.

2. Comment. Please update the ticker symbols on Edgar once available.

Response. The Trust confirms that ticker symbols will be updated on Edgar once available.

3. Comment. Please update the Fund’s “Interest Rate Risk” disclosure, taking into consideration current market conditions.

Response. The requested change has been made.

4. Comment. Please revise the Item 4(b)(1)(ii)(B) disclosure to more closely align with the requirements of Form N-1A.

Response. The requested change has been made.

5. Comment. Please revise the first full paragraph in the “Performance Information” section to disclose that, because Sweep Class shares have higher expenses than Class F shares, performance for Sweep Class shares would have been lower than that of Class F shares.

Response. The requested change has been made.

6. Comment. In the third paragraph in the “More Information About Investments” section, please specifically identify “government securities,” rather than “the types of securities described in this prospectus.”

Response. The requested change has been made.

7. Comment. In the “Financial Highlights” section, please include the financial highlights of at least one existing share class of the Fund.

Response. The requested change has been made.

8. Comment. With respect to the second item in the “Non-Fundamental Policies” section of the SAI, please confirm whether the reference to “domestic banks and U.S. branches of foreign banks” should be limited to the deposit instruments of such entities and, if so, please revise accordingly.

Response. The Trust expects to revise this Non-Fundamental Policy, subject to Board approval at its next regularly scheduled meeting on January 25, 2023, to clarify that the limitation does not apply to “certificates of deposit, commercial paper, bankers’ acceptances or similar instruments issued or guaranteed by” such banks and bank branches.

9. Comment. In the “Senior Securities” section of the SAI, please delete “with appropriate earmarking or segregation of assets to cover such obligation, to the extent applicable.”

Response. The requested change has been made.

If you have any questions, need any additional information or would like any clarification, please contact me at (215) 963-5266.

Very
truly yours,
/s/
Jessica L. Accurso

Show Raw Text
CORRESP
1
filename1.htm

Jessica L.
Accurso

Associate

215.963.5266

December 27,
2022

FILED AS EDGAR CORRESPONDENCE

Matthew S. Williams, Esq.

U.S. Securities and Exchange Commission

Division of Investment Management

100
F Street, NE

Washington, D.C. 20549

Re:          Response
letter to comments on Post-Effective Amendment No. 92 to the Registration Statement of SEI Daily Income Trust (File Nos. 002-77048
and 811-03451)

Dear Mr. Williams:

On behalf of our
client, SEI Daily Income Trust (the “Trust” or “SDIT”), this letter responds to the comments and questions you
provided via telephone on December 9, 2022, regarding the Trust’s Post-Effective Amendment No. 92, under the Securities
Act of 1933, as amended (the “1933 Act”), and Amendment No. 91, under the Investment Company Act of 1940, as amended
(the “1940 Act”), to its Registration Statement filed with the SEC on October 28, 2022 pursuant to Rule 485(a)(1) under
the 1933 Act (the “Amendment”), for the purpose of introducing a new share class of the Government Fund (the “Fund”),
a series of the Trust. As indicated in the Amendment, SEI Investments Management Corporation (“SIMC” or the “Adviser”)
serves as investment adviser to the Fund. Below, we have briefly summarized your comments and questions, followed by our responses. Capitalized
terms not defined herein should be given the meaning provided in the Amendment.

 1. Comment.              The
                                            Staff notes that when a comment is made in one location, it is applicable to all similar
                                            disclosure appearing elsewhere in the registration statement.

  Response.             Acknowledged.

 2. Comment.             Please
                                            update the ticker symbols on Edgar once available.

  Response.             The
                                            Trust confirms that ticker symbols will be updated on Edgar once available.

 3. Comment.             Please
                                            update the Fund’s “Interest Rate Risk” disclosure, taking into consideration
                                            current market conditions.

  Response.             The
                                            requested change has been made.

 4. Comment.             Please
                                            revise the Item 4(b)(1)(ii)(B) disclosure to more closely align with the requirements
                                            of Form N-1A.

  Response.
                                                         The
                                            requested change has been made.

 5. Comment.             Please
                                            revise the first full paragraph in the “Performance Information” section to disclose
                                            that, because Sweep Class shares have higher expenses than Class F shares, performance
                                            for Sweep Class shares would have been lower than that of Class F shares.

  Response.             The
                                            requested change has been made.

 6. Comment.             In
                                            the third paragraph in the “More Information About Investments” section, please
                                            specifically identify “government securities,” rather than “the types of
                                            securities described in this prospectus.”

  Response.             The
                                            requested change has been made.

 7. Comment.             In
                                            the “Financial Highlights” section, please include the financial highlights of
                                            at least one existing share class of the Fund.

  Response.             The
                                            requested change has been made.

 8. Comment.             With
                                            respect to the second item in the “Non-Fundamental Policies” section of the SAI,
                                            please confirm whether the reference to “domestic banks and U.S. branches of foreign
                                            banks” should be limited to the deposit instruments of such entities and, if so, please
                                            revise accordingly.

  Response.             The
                                            Trust expects to revise this Non-Fundamental Policy, subject to Board approval at its next
                                            regularly scheduled meeting on January 25, 2023, to clarify that the limitation does
                                            not apply to “certificates of deposit, commercial paper, bankers’ acceptances or similar instruments
                                            issued or guaranteed by” such banks and bank branches.

 9. Comment.             In
                                            the “Senior Securities” section of the SAI, please delete “with appropriate
                                            earmarking or segregation of assets to cover such obligation, to the extent applicable.”

  Response.             The
                                            requested change has been made.

If
you have any questions, need any additional information or would like any clarification, please contact me at (215) 963-5266.

Very
truly yours,

/s/
Jessica L. Accurso

Jessica
L. Accurso

      2