Correspondence 0000770200-23-000008 from Midas Series Trust (CIK 0000770200)
Midas Series Trust (CIK 0000770200)
Date: April 6, 2023 · CIK: 0000770200 · Accession: 0000770200-23-000008
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File numbers found in text: 811-04316
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CORRESP
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filename1.htm
Midas Series Trust
2255 Buffalo Road
Rochester, NY 14624
April 6, 2023
VIA EDGAR CORRESPONDENCE
Deborah L. O’Neal
Division of Investment Management, Disclosure Review Office
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Response to Comments on Post-Effective Amendment No. 74 (the “Post-Effective Amendment”) to the Registration Statement of Midas Series Trust (the “Registrant” or
“Fund”) (002-98229; 811-04316)
Dear Ms. O’Neal:
On behalf of the Registrant, set forth below are the comments that you (the “Staff”) provided by email on April 5,
2023 concerning the Fund’s Post-Effective Amendment which was filed with the Securities and Exchange Commission (the “SEC”) on February 27, 2023, and the Registrant’s response thereto.
1.
Comment: Given the
pivot/flexibility in the fund’s principal investment strategy, consider highlighting the disclosure on page 2 that states, “provided, however, that the Fund’s investment adviser . . . . may invest in any type of equity security (e.g.,
common and preferred stocks)” with bold or italicized font.
Response: The Fund will make
the requested change.
* * * * *
Should you have any further comments on these matters, or any questions, please contact me at (212) 785-0900, extension 275, or
rkamerman@midasfunds.com.
Sincerely,
MIDAS SERIES TRUST
By:
/s/Russell Kamerman
Name:
Russell Kamerman
Title:
General Counsel
cc:
Pamela M. Krill, Esq.
Godfrey & Kahn, S.C.