Correspondence 0000894189-23-003766 from PROFESSIONALLY MANAGED PORTFOLIOS (CIK 0000811030)
PROFESSIONALLY MANAGED PORTFOLIOS (CIK 0000811030)
Date: May 17, 2023 · CIK: 0000811030 · Accession: 0000894189-23-003766
AI Filing Summary & Sentiment
File numbers found in text: 811-05037
Letter
VIA EDGAR TRANSMISSION Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Professionally Managed Portfolios (the “Trust”) File Nos.: 33-12213 and 811-05037
Dear Ms. Miller:
This correspondence responds to the comments the Trust received from the staff of the Commission (the “Staff”) on May 8, 2023, with respect to recent Form N-CSR and Form N-CEN filings and registration statements for the series of the Trust and their respective fiscal year ends as set forth in the table below (each, a “Fund” and collectively, the “Funds”):
Series ID Series Name FYE Reviewed
S000004945 Trillium ESG Global Equity Fund 6/30/2022
S000050271 Trillium ESG Small/Mid Cap Fund 6/30/2022
S000026760 Akre Focus Fund 7/31/2022
S000070633 Boston Common ESG Impact Emerging Markets Fund 9/30/2022
S000030907 Boston Common ESG Impact International Fund 9/30/2022
S000030908 Boston Common ESG Impact U.S. Equity Fund 9/30/2022
S000004936 TCM Small Cap Growth Fund 9/30/2022
S000037988 Becker Value Equity Fund 10/31/2022
S000025205 Congress Large Cap Growth Fund 10/31/2022
S000038711 Congress Mid Cap Growth Fund 10/31/2022
S000058028 Congress Small Cap Growth Fund 10/31/2022
S000036430 Muzinich Credit Opportunities Fund 12/31/2022
S000036428 Muzinich High Income Floating Rate Fund 12/31/2022
S000054438 Muzinich Low Duration Fund 12/31/2022
S000036429 Muzinich U.S. High Yield Credit Fund 12/31/2022
For your convenience, the comments have been reproduced with a response following each comment.
Comment 1. With respect to the Trillium Funds filing on Form N-CEN, the Staff notes that the “Report of Independent Registered Public Accounting Firm” exhibit submitted with the filing was not signed by the audit firm. Please submit an amended filing on Form N-CEN and include a signed report from the audit firm as an exhibit to the amended filing.
Response: The Trust confirms that it will submit an amended filing on Form N-CEN for the Trillium Funds via EDGAR and include a signed report from the audit firm as an exhibit to the amended filing.
Comment 2. With respect to the annual reports for the FYE’s 9/30 and 10/31 filed on Form N-CSR for the Boston Common Funds, Becker Value Equity Fund, and Congress Funds, the Notes to the Financial Statements state the funds have certain commitments and contingencies, however the balance sheet does not have disclosure either by amount or by a line item that references the Notes to the Financial Statements. Please include these references in future filings.
Response: The Trust confirms that the requested change will be made in future shareholder reports.
Comment 3. With respect to the annual report filed on Form N-CSR for the Muzinich Funds, in the Notes to Financial Statements, Note 1 - Organization, the disclosure provides four separate commencement of operation dates when there are only three active funds. Please revise in future filings. See Regulation S-X 6-04.15.
Response: The Trust confirms that the requested change will be made in future shareholder reports.
Comment 4. Item 4(d) of the registrant’s certification required by Item 13(a)(2) of Form N-CSR does not refer to the correct time period for the Akre Focus Fund, Boston Common Funds, and Muzinich Funds. Please file an amended Form N-CSR to include the correct form of certification and ensure the form of certification is updated to be accurate.
Response: The Trust confirms that it will submit amended filings on Form N-CSR for the Akre Focus Fund, Boston Common Funds, and Muzinich Funds via EDGAR and include an updated form of certification to these amended filings.
If you have any questions regarding the enclosed, please do not hesitate to contact the undersigned at (414) 516-1716 or carl.gee@usbank.com.
Sincerely,
/s/ Carl G. Gee
Show Raw Text
CORRESP 1 filename1.htm Document Professionally Managed Portfolios c/o U.S. Bank Global Fund Services 777 East Wisconsin Avenue Milwaukee, WI 53202 May 17, 2023 VIA EDGAR TRANSMISSION Ms. Megan Miller U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Professionally Managed Portfolios (the “Trust”) File Nos.: 33-12213 and 811-05037 Dear Ms. Miller: This correspondence responds to the comments the Trust received from the staff of the Commission (the “Staff”) on May 8, 2023, with respect to recent Form N-CSR and Form N-CEN filings and registration statements for the series of the Trust and their respective fiscal year ends as set forth in the table below (each, a “Fund” and collectively, the “Funds”): Series ID Series Name FYE Reviewed S000004945 Trillium ESG Global Equity Fund 6/30/2022 S000050271 Trillium ESG Small/Mid Cap Fund 6/30/2022 S000026760 Akre Focus Fund 7/31/2022 S000070633 Boston Common ESG Impact Emerging Markets Fund 9/30/2022 S000030907 Boston Common ESG Impact International Fund 9/30/2022 S000030908 Boston Common ESG Impact U.S. Equity Fund 9/30/2022 S000004936 TCM Small Cap Growth Fund 9/30/2022 S000037988 Becker Value Equity Fund 10/31/2022 S000025205 Congress Large Cap Growth Fund 10/31/2022 S000038711 Congress Mid Cap Growth Fund 10/31/2022 S000058028 Congress Small Cap Growth Fund 10/31/2022 S000036430 Muzinich Credit Opportunities Fund 12/31/2022 S000036428 Muzinich High Income Floating Rate Fund 12/31/2022 S000054438 Muzinich Low Duration Fund 12/31/2022 S000036429 Muzinich U.S. High Yield Credit Fund 12/31/2022 For your convenience, the comments have been reproduced with a response following each comment. Comment 1. With respect to the Trillium Funds filing on Form N-CEN, the Staff notes that the “Report of Independent Registered Public Accounting Firm” exhibit submitted with the filing was not signed by the audit firm. Please submit an amended filing on Form N-CEN and include a signed report from the audit firm as an exhibit to the amended filing. Response: The Trust confirms that it will submit an amended filing on Form N-CEN for the Trillium Funds via EDGAR and include a signed report from the audit firm as an exhibit to the amended filing. 1 Comment 2. With respect to the annual reports for the FYE’s 9/30 and 10/31 filed on Form N-CSR for the Boston Common Funds, Becker Value Equity Fund, and Congress Funds, the Notes to the Financial Statements state the funds have certain commitments and contingencies, however the balance sheet does not have disclosure either by amount or by a line item that references the Notes to the Financial Statements. Please include these references in future filings. Response: The Trust confirms that the requested change will be made in future shareholder reports. Comment 3. With respect to the annual report filed on Form N-CSR for the Muzinich Funds, in the Notes to Financial Statements, Note 1 - Organization, the disclosure provides four separate commencement of operation dates when there are only three active funds. Please revise in future filings. See Regulation S-X 6-04.15. Response: The Trust confirms that the requested change will be made in future shareholder reports. Comment 4. Item 4(d) of the registrant’s certification required by Item 13(a)(2) of Form N-CSR does not refer to the correct time period for the Akre Focus Fund, Boston Common Funds, and Muzinich Funds. Please file an amended Form N-CSR to include the correct form of certification and ensure the form of certification is updated to be accurate. Response: The Trust confirms that it will submit amended filings on Form N-CSR for the Akre Focus Fund, Boston Common Funds, and Muzinich Funds via EDGAR and include an updated form of certification to these amended filings. If you have any questions regarding the enclosed, please do not hesitate to contact the undersigned at (414) 516-1716 or carl.gee@usbank.com. Sincerely, /s/ Carl G. Gee Carl G. Gee, Esq. Vice President & Secretary of the Trust 2