SEC Company Response from WILLIAMSBURG INVESTMENT TRUST (CIK 0000842512) — Feb 5, 2026
WILLIAMSBURG INVESTMENT TRUST (CIK 0000842512)
Date: Feb. 5, 2026 · CIK: 0000842512 · Accession: 0001580642-26-000808
AI Filing Summary & Sentiment
File numbers found in text: 811-05685
Letter
Division of Investment Management New York, NY 10004-2616 Re: Williamsburg Investment Trust (the “Trust”) File Nos. 811-05685; 33-25301 Response to Comments from SOX Review for the Fiscal Year Ended March 31, 2025
Dear Ms. Rotter:
Set forth below is the Trust’s response to oral comments provided by the Division of Investment Management’s staff (the “Staff”) of the U.S. Securities and Exchange Commission on January 23, 2026, on the Trust’s annual shareholder report on Form N-CSR for the fiscal year ending March 31, 2025 (“Fiscal Year”) with respect to Davenport Core Leaders Fund, Davenport Value & Income Fund, Davenport Equity Opportunities Fund, Davenport Small Cap Focus Fund, Davenport Balanced Income Fund, Davenport Insider Buying Fund, Government Street Equity Fund, Government Street Opportunities Fund, and Jamestown Equity Fund, each a series of the Trust (together, the “Funds”). For your convenience, the Staff’s comments are set forth below in italics, followed by the Trust’s response.
Notes to Financial Statements
1. Note 1 to the audited financial statements for all of the Funds reviewed noted disclosure regarding the Funds’ chief operating decision maker (“CODM”) and it appears that the adviser has been identified as the chief operating decision maker for its respective managed funds. Please explain in correspondence how the selection of the investment adviser complies with FASC 280-10-50-5. If the disclosure provided in Note 1 needs to be updated, please confirm that such update will be provided in future filings.
Response: The Registrant appreciates the Staff’s comment and notes the referenced disclosure will be updated in the Registrant’s Form N-CSR filing for the fiscal year ended March 31, 2026 to reflect that the CODM for each Fund is the management team of the investment adviser.
Diversification Status
2. Please confirm in correspondence that Davenport Equity Opportunities Fund, identified as a non-diversified fund in Form N-CEN, continues to maintain its non-diversified status. Staff notes that if a fund operates as a diversified fund for more than 3 years, it will require shareholder approval to change its status back to a non-diversified fund.
RESPONSE:
Response: The Trust confirms that Davenport Equity Opportunities Fund continues to maintain its non-diversified status and has not operated as a diversified fund for more than 3 years. The Trust notes that the Fund’s diversification status is monitored on a daily basis.
Thank you for your comments. If you have any questions, please contact me at (513) 326-3586.
Very truly yours,
/s/Jennifer Merchant
Show Raw Text
CORRESP
1
filename1.htm
Williamsburg Investment Trust
225 Pictoria Drive, Suite 450
Cincinnati, Ohio 45246
February 5, 2026
FILED VIA EDGAR
Ms. Mindy Rotter, Esq., CPA
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Re: Williamsburg Investment Trust (the “Trust”)
File Nos. 811-05685; 33-25301
Response to Comments
from SOX Review for the Fiscal Year Ended March 31, 2025
Dear Ms. Rotter:
Set forth below is the Trust’s response to oral
comments provided by the Division of Investment Management’s staff (the “Staff”) of the U.S. Securities and Exchange
Commission on January 23, 2026, on the Trust’s annual shareholder report on Form N-CSR for the fiscal year ending March 31, 2025
(“Fiscal Year”) with respect to Davenport Core Leaders Fund, Davenport Value & Income Fund, Davenport Equity Opportunities
Fund, Davenport Small Cap Focus Fund, Davenport Balanced Income Fund, Davenport Insider Buying Fund, Government Street Equity Fund, Government
Street Opportunities Fund, and Jamestown Equity Fund, each a series of the Trust (together, the “Funds”). For your convenience,
the Staff’s comments are set forth below in italics, followed by the Trust’s response.
Notes to Financial Statements
1. Note 1 to the audited financial statements for all of the Funds reviewed noted disclosure regarding
the Funds’ chief operating decision maker (“CODM”) and it appears that the adviser has been identified as the chief
operating decision maker for its respective managed funds. Please explain in correspondence how the selection of the investment adviser
complies with FASC 280-10-50-5. If the disclosure provided in Note 1 needs to be updated, please confirm that such update will be provided
in future filings.
1
Response: The Registrant appreciates
the Staff’s comment and notes the referenced disclosure will be updated in the Registrant’s Form N-CSR filing for the fiscal
year ended March 31, 2026 to reflect that the CODM for each Fund is the management team of the investment adviser.
Diversification Status
2. Please confirm in correspondence that Davenport Equity Opportunities Fund, identified as a non-diversified fund in Form N-CEN,
continues to maintain its non-diversified status. Staff notes that if a fund operates as a diversified fund for more than 3 years, it
will require shareholder approval to change its status back to a non-diversified fund.
RESPONSE:
Response: The Trust confirms that
Davenport Equity Opportunities Fund continues to maintain its non-diversified status and has not operated as a diversified fund for more
than 3 years. The Trust notes that the Fund’s diversification status is monitored on a daily basis.
Thank you for your comments. If you have any questions, please contact
me at (513) 326-3586.
Very truly yours,
/s/Jennifer Merchant
Jennifer L. Merchant
Assistant Secretary
cc: John L. Chilton, Esq. Sullivan and Worcester LLP
Ultimus Fund Solutions, LLC
225 Pictoria Drive, Suite 450
Phone: 513 587 3400
www.ultimusfundsolutions.com
Cincinnati, Ohio 45246
Fax: 513 587 3450
2