Correspondence 0001137439-25-000104 from DFA INVESTMENT TRUST CO (CIK 0000896162)
DFA INVESTMENT TRUST CO (CIK 0000896162)
Date: Feb. 20, 2025 · CIK: 0000896162 · Accession: 0001137439-25-000104
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File numbers found in text: 811-7436
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CORRESP
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February 20, 2025
Via EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
Judiciary Plaza–Room 5422
100 F Street, N.E.
Washington, D.C. 20549-9303
Attention: Ms. Emily Rowland
Re:
The DFA Investment Trust Company
File No. 811-7436
Dear Ms. Rowland:
On behalf of The DFA Investment Trust Company (the “Registrant”), the following are the responses to the Staff’s comments conveyed with
regard to Amendment No 78 to the Registration Statement of the Registrant (the “Amendment”), filed with the U.S. Securities and Exchange Commission (the “SEC”) on August 1, 2024, pursuant to the Investment Company Act of 1940, as amended (the “1940
Act”).
Each SEC Staff comment is summarized below, followed by the Registrant’s response to the comment. Capitalized terms not otherwise
defined in this letter have the meanings assigned to the terms in the Amendment. The Registrant understands that the Registrant and management are responsible for the accuracy and adequacy of the disclosures notwithstanding any review comment or
action of the Staff of the SEC.
1. Comment. In the first paragraph under “INVESTMENT OBJECTIVE AND POLICIES—THE DFA SHORT
TERM INVESTMENT FUND,” please revise the list of investments disclosed in the paragraph to match the investments itemized under “Description of Investments.”
Response. The Registrant has revised the
paragraph to include investments in foreign government and agency and supranational organization obligations to match the list of investments included under “Description of Investments.”
2. Comment. The DFA Short Term Investment Fund (the “Fund”) does not list foreign
currency risk as one of its investment risks. Please clarify under “Description of Investments” that the foreign issuer obligations that the Fund invests in are U.S. dollar denominated investments and, thus, are not subject to foreign currency
risk.
Response. The Registrant has revised the
disclosure to clarify that the Fund invests in U.S. dollar-denominated debt securities of non-U.S. issuers.
3. Comment. The disclosure in the “Investments in the Banking Industry” section states
that the Fund, if attempting to respond to adverse market, economic, political, or other conditions, may, from time to time, invest less than 25% of its total assets in banking industry securities as a temporary defensive measure. Please include
disclosure that the effect of the Fund taking temporary defensive measures may include not achieving the Fund’s investment objective.
Response. The Registrant has revised the
disclosure accordingly.
4. Comment. Please consider adding a risk factor for the Fund with respect to investing
in money market funds.
Response. The Fund respectfully declines to
add an additional risk factor because the Fund already currently discloses that investing in a money market fund may involve a duplication of certain fees and expenses.
5. Comment. Please clarify that the China Investments Risk does not apply to the Fund or
list the series of the Registrant for which China Investments Risk is applicable.
Response. The disclosure has been revised to
include a sentence to identify the series of the Registrant for which China Investments Risk is applicable.
6. Comment. Please add “Like the other Series of the Trust” to begin the first sentence
under the heading, “Investments in the Short Term Series.”
Response. The Registrant has revised the
disclosure accordingly.
7. Comment. “Asset-Backed Securities Risk” is identified as a risk for the Fund, please
include asset backed securities as a permitted investment in the principal strategies section.
Response. The Registrant has revised the
disclosure accordingly.
8. Comment. In “Item 9(d) Portfolio Holdings,” it is stated that each Series, other than
the Fund, will disclose up to its twenty-five largest portfolio holdings (other than cash or cash equivalents) on its website. Please explain supplementally why the Fund does not disclose its twenty-five largest holdings on the website.
Response. All series of the Registrant have
not been registered under the Securities Act of 1933, which means that their shares may not be sold publicly. In contrast to the other series of the Registrant, however, the Fund is not a master fund for a feeder fund registered under the Securities
Act of 1933. Accordingly, due to this investment profile and not being sold publicly, the Fund does not post its twenty-five largest holdings on the website.
9. Comment. Since the Fund will invest in sovereign debt, please clarify that
investments in sovereign debt of any single country are considered a single industry for purposes of the concentration limitation.
Response. The following disclosure will be
added to the registration statement with respect to the concentration limitations:
“For purposes of the investment limitations described in (9) and (10) above, management does not consider securities that are
issued by the U.S. Government or its agencies or instrumentalities to be investments in an “industry.” However, management currently considers securities issued by a foreign government (but not the U.S. Government or its agencies or
instrumentalities) to be an “industry” subject to the 25% limitation. Thus, not more than 25% of a Series’ assets will be invested in securities issued by any one foreign government or supranational organization.”
10. Comment. Please supplementally confirm that the Fund is carved out from the section
entitled “Cash Management Practices.”
Response. The Registrant supplementally
confirms that the Fund is carved out of the section entitled “Cash Management Practices.” The “Cash Management Practices” section describes the short-term cash equivalents and similar investments that other series of the Registrant may purchase to
manage uncommitted cash. Because the Fund may invest in cash equivalents and similar investments as part of its principal investment strategies, which is discussed in the Fund’s Item 9 disclosure, the “Cash Management Practices” section is not
applicable to the Fund.
* * * * * *
Please do not hesitate to contact Ms. Cresswell at (215) 564-8048, if you have any questions or
wish to discuss any of the responses presented above.
Very truly yours,
/s/ Ryan P. Buechner
Ryan P. Buechner, Esq.
Vice President and Assistant Secretary
The DFA Investment Trust Company