SEC Company Response from SUNAMERICA SERIES TRUST (CIK 0000892538) — Feb 5, 2021
SUNAMERICA SERIES TRUST (CIK 0000892538)
Date: Feb. 5, 2021 · CIK: 0000892538 · Accession: 0001193125-21-030929
AI Filing Summary & Sentiment
File numbers found in text: 333-251638
Letter
VIA EDGAR Securities and Exchange Commission Washington, D.C. 20549 Pre-Effective Amendment No. 1 Securities Act File No. 333-251638
Re: SunAmerica Series Trust – SA VCP Dynamic Strategy Portfolio
Dear Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, SunAmerica Series Trust (the “Registrant”) requests acceleration of the effective date of Pre-Effective Amendment No. 1 to its Registration Statement on Form N-14 (File No. 333-251638) (the “Amendment”) so that the Amendment is declared effective on Tuesday, February 9, 2021, or as soon as practicable thereafter. AIG Capital Services, Inc., the principal underwriter of the Registrant, hereby joins in its request for acceleration of the effectiveness of the Amendment.
If this request is granted, we respectfully request that we be notified by telephone at the time of effectiveness, and that such effectiveness also be confirmed in writing. Please call Stacey P. Ruiz of Willkie Farr & Gallagher LLP at (212) 728-8037.
The Registrant hereby acknowledges that, if the Securities and Exchange Commission (the “Commission”) (or its staff, acting pursuant to delegated authority), declares the filing effective, such action:
(i) does not foreclose the Commission from taking any action with respect to the filing;
(ii) does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
(iii) may not be asserted by the Registrant as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
February 5, 2021
Page
Very truly yours,
SunAmerica Series Trust
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CORRESP 1 filename1.htm CORRESP February 5, 2021 VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: SunAmerica Series Trust – SA VCP Dynamic Strategy Portfolio Pre-Effective Amendment No. 1 Securities Act File No. 333-251638 Dear Commissioners: Pursuant to Rule 461 under the Securities Act of 1933, SunAmerica Series Trust (the “Registrant”) requests acceleration of the effective date of Pre-Effective Amendment No. 1 to its Registration Statement on Form N-14 (File No. 333-251638) (the “Amendment”) so that the Amendment is declared effective on Tuesday, February 9, 2021, or as soon as practicable thereafter. AIG Capital Services, Inc., the principal underwriter of the Registrant, hereby joins in its request for acceleration of the effectiveness of the Amendment. If this request is granted, we respectfully request that we be notified by telephone at the time of effectiveness, and that such effectiveness also be confirmed in writing. Please call Stacey P. Ruiz of Willkie Farr & Gallagher LLP at (212) 728-8037. The Registrant hereby acknowledges that, if the Securities and Exchange Commission (the “Commission”) (or its staff, acting pursuant to delegated authority), declares the filing effective, such action: (i) does not foreclose the Commission from taking any action with respect to the filing; (ii) does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) may not be asserted by the Registrant as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. February 5, 2021 Page 2 Very truly yours, SunAmerica Series Trust By: /s/ John T. Genoy Name: John T. Genoy Title: President AIG Capital Services, Inc. By: /s/ James T. Nichols Name: James T. Nichols Title: Director, President and Chief Executive Officer - 2 -