SEC Company Response from FIDELITY ABERDEEN STREET TRUST (CIK 0000880195) — Jan 5, 2026
FIDELITY ABERDEEN STREET TRUST (CIK 0000880195)
Date: Jan. 5, 2026 · CIK: 0000880195 · Accession: 0000880195-26-000003
AI Filing Summary & Sentiment
File numbers found in text: 811-06440
Letter
Converted by EDGARwiz
COMMENTS RECEIVED ON 12/18/2025
FROM RYAN SUTCLIFFE
FIDELITY ABERDEEN STREET TRUST (File Nos. 033-43529 and 811-06440)
Fidelity Freedom Retirement Fund, Fidelity Freedom 2010 Fund, Fidelity Freedom 2015 Fund, Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, Fidelity Freedom 2030 Fund, Fidelity Freedom 2035 Fund, Fidelity Freedom 2040 Fund, Fidelity Freedom 2045 Fund, Fidelity Freedom 2050 Fund, Fidelity Freedom 2055 Fund, Fidelity Freedom 2060 Fund, Fidelity Freedom 2065 Fund, Fidelity Freedom 2070 Fund
POST-EFFECTIVE AMENDMENT NO. 171
All funds
“Fund Summary” (prospectus)
“Fee Table”
C:
The Staff notes that there appears to be a fee waiver in operation for the Premier Class and requests that we include a footnote to each fee table discussing the waiver, including dates related thereto and termination provisions. The Staff may have additional comments depending on the response.
R:
As noted in the “Fund Services – Fund Management – Advisory Fee(s)” section of the prospectus and the "Management Contracts - Management-Related Expenses" section of the SAI, each fund has in place an expense contract for Premier Class of the fund. These expense contracts do not contain a termination date. Each fund will add the following footnote to the Premier Class fee table related to the expense contract:
“The management fee rate is subject to the expense contract arrangements discussed in greater detail in the “Fund Services – Fund Management – Advisory Fee(s)” section of the prospectus and the "Management Contracts - Management-Related Expenses" section of the SAI.”
COMMENTS RECEIVED ON 12/30/2025
FROM RYAN SUTCLIFFE
FIDELITY ABERDEEN STREET TRUST (File Nos. 033-43529 and 811-06440)
Fidelity Freedom Retirement Fund, Fidelity Freedom 2010 Fund, Fidelity Freedom 2015 Fund, Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, Fidelity Freedom 2030 Fund, Fidelity Freedom 2035 Fund, Fidelity Freedom 2040 Fund, Fidelity Freedom 2045 Fund, Fidelity Freedom 2050 Fund, Fidelity Freedom 2055 Fund, Fidelity Freedom 2060 Fund, Fidelity Freedom 2065 Fund, Fidelity Freedom 2070 Fund
POST-EFFECTIVE AMENDMENT NO. 171
All funds
“Fund Summary” (prospectus)
“Fee Table”
C:
The Staff reiterates the request that we include a standard management fee waiver footnote on the basis that there is a management fee waiver. The Staff also clarified that they request a waiver line item be included in the fee table.
R:
We believe the proposed new footnote appropriately refers to the expense contract arrangements in place for Premier Class of each fund. As a result, we do not believe additional changes to the fee tables are necessary.
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CORRESP 1 filename1.htm Converted by EDGARwiz COMMENTS RECEIVED ON 12/18/2025 FROM RYAN SUTCLIFFE FIDELITY ABERDEEN STREET TRUST (File Nos. 033-43529 and 811-06440) Fidelity Freedom Retirement Fund, Fidelity Freedom 2010 Fund, Fidelity Freedom 2015 Fund, Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, Fidelity Freedom 2030 Fund, Fidelity Freedom 2035 Fund, Fidelity Freedom 2040 Fund, Fidelity Freedom 2045 Fund, Fidelity Freedom 2050 Fund, Fidelity Freedom 2055 Fund, Fidelity Freedom 2060 Fund, Fidelity Freedom 2065 Fund, Fidelity Freedom 2070 Fund POST-EFFECTIVE AMENDMENT NO. 171 All funds “Fund Summary” (prospectus) “Fee Table” C: The Staff notes that there appears to be a fee waiver in operation for the Premier Class and requests that we include a footnote to each fee table discussing the waiver, including dates related thereto and termination provisions. The Staff may have additional comments depending on the response. R: As noted in the “Fund Services – Fund Management – Advisory Fee(s)” section of the prospectus and the "Management Contracts - Management-Related Expenses" section of the SAI, each fund has in place an expense contract for Premier Class of the fund. These expense contracts do not contain a termination date. Each fund will add the following footnote to the Premier Class fee table related to the expense contract: “The management fee rate is subject to the expense contract arrangements discussed in greater detail in the “Fund Services – Fund Management – Advisory Fee(s)” section of the prospectus and the "Management Contracts - Management-Related Expenses" section of the SAI.” COMMENTS RECEIVED ON 12/30/2025 FROM RYAN SUTCLIFFE FIDELITY ABERDEEN STREET TRUST (File Nos. 033-43529 and 811-06440) Fidelity Freedom Retirement Fund, Fidelity Freedom 2010 Fund, Fidelity Freedom 2015 Fund, Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, Fidelity Freedom 2030 Fund, Fidelity Freedom 2035 Fund, Fidelity Freedom 2040 Fund, Fidelity Freedom 2045 Fund, Fidelity Freedom 2050 Fund, Fidelity Freedom 2055 Fund, Fidelity Freedom 2060 Fund, Fidelity Freedom 2065 Fund, Fidelity Freedom 2070 Fund POST-EFFECTIVE AMENDMENT NO. 171 All funds “Fund Summary” (prospectus) “Fee Table” C: The Staff reiterates the request that we include a standard management fee waiver footnote on the basis that there is a management fee waiver. The Staff also clarified that they request a waiver line item be included in the fee table. R: We believe the proposed new footnote appropriately refers to the expense contract arrangements in place for Premier Class of each fund. As a result, we do not believe additional changes to the fee tables are necessary.