SEC Company Response from PROFESSIONALLY MANAGED PORTFOLIOS (CIK 0000811030) — Dec 18, 2024
PROFESSIONALLY MANAGED PORTFOLIOS (CIK 0000811030)
Date: Dec. 18, 2024 · CIK: 0000811030 · Accession: 0000894189-24-007379
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 811-05037
Letter
VIA EDGAR TRANSMISSION Division of Investment Management Washington, D.C. 20549 Re: Professionally Managed Portfolios (the “Trust”) Securities Act Registration No: 033-12213 Investment Company Act Registration No: 811-05037
Dear Ms. Miller:
On behalf of Otter Creek Long/Short Opportunity Fund, Osterweis Fund, Osterweis Strategic Income Fund, Osterweis Growth & Income Fund, and Osterweis Opportunity Fund (formerly: Osterweis Emerging Opportunity Fund) (the “Funds”), each a series of the Trust, set forth below are the Trust’s responses to the comments received from you on November 21, 2024, with respect to the review of Funds’ financial statements as of 10/31/2023 and 3/31/2024, as applicable. For your convenience, your comments have been reproduced with a response following the comment.
Comment No. 1: Please explain in correspondence with regard to the Osterweis Strategic Income Fund and the Osterweis Growth & Income Fund why the disclosure regarding the weighted average significant unobservable inputs were excluded for level 3 securities.
Response: The Input Values included in the table were static during the period and therefore there was no weighted average to display. The Trust acknowledges that this was not specifically disclosed and will add the weighted average or other appropriate disclosures going forward.
Comment No. 2: According to note 3, in the notes to the financial statements for the Otter Creek Long/Short Opportunity Fund and the Osterweis Funds, certain of the Funds have commitments and contingencies for recoupment, these include the disclosures in Regulation S-X, Rule 6-04.15.
Response: A commitment or contingency will be added going forward when applicable.
If you have any questions regarding the enclosed, please do not hesitate to contact the undersigned at (626) 914-7363 or elaine.richards@usbank.com.
Sincerely,
/s/ Elaine E. Richards
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CORRESP 1 filename1.htm Document Professionally Managed Portfolios c/o U.S. Bank Global Fund Services 615 East Michigan Street Milwaukee, Wisconsin 53202 December 18, 2024 VIA EDGAR TRANSMISSION Ms. Megan Miller U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Professionally Managed Portfolios (the “Trust”) Securities Act Registration No: 033-12213 Investment Company Act Registration No: 811-05037 Dear Ms. Miller: On behalf of Otter Creek Long/Short Opportunity Fund, Osterweis Fund, Osterweis Strategic Income Fund, Osterweis Growth & Income Fund, and Osterweis Opportunity Fund (formerly: Osterweis Emerging Opportunity Fund) (the “Funds”), each a series of the Trust, set forth below are the Trust’s responses to the comments received from you on November 21, 2024, with respect to the review of Funds’ financial statements as of 10/31/2023 and 3/31/2024, as applicable. For your convenience, your comments have been reproduced with a response following the comment. Comment No. 1: Please explain in correspondence with regard to the Osterweis Strategic Income Fund and the Osterweis Growth & Income Fund why the disclosure regarding the weighted average significant unobservable inputs were excluded for level 3 securities. Response: The Input Values included in the table were static during the period and therefore there was no weighted average to display. The Trust acknowledges that this was not specifically disclosed and will add the weighted average or other appropriate disclosures going forward. Comment No. 2: According to note 3, in the notes to the financial statements for the Otter Creek Long/Short Opportunity Fund and the Osterweis Funds, certain of the Funds have commitments and contingencies for recoupment, these include the disclosures in Regulation S-X, Rule 6-04.15. Response: A commitment or contingency will be added going forward when applicable. If you have any questions regarding the enclosed, please do not hesitate to contact the undersigned at (626) 914-7363 or elaine.richards@usbank.com. Sincerely, /s/ Elaine E. Richards Elaine E. Richards Vice President & Secretary of the Trust