SEC Comment Letter for BANK OF MONTREAL (BMO) — Jun 10, 2016
BANK OF MONTREAL /CAN/ (BMO, BERZ, BNKD, BNKU, BULZ, CARD, CARU, DULL, FLYD, FLYU, FNGD, FNGO, FNGS, FNGU, GDXD, GDXU, JETD) (CIK 0000927971)
Date: June 10, 2016 · CIK: 0000927971 · Accession: 0000000000-16-080111
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-211858
Letter
Mail Stop 3233 June 9, 2016 Via E -mail Colleen Hennessy Bank of Montreal 111 West Monroe Street P. O. Box 755 Chicago, Illinois 60690
Re: Vaulted Gold Bullion Trust Registration Statement on Form S-1 Filed June 6, 2016 File No. 333-211858
Dear Ms. Hennessy:
We have reviewed your amended registration statement and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not bel ieve an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
General
1. Please revise your disclosure to describe the risk that the execution price that an investor obtains could differ from the last price quote received. Please also revise your disclosure to discuss generally the expected time period between an investor placing an order and the trade being executed, as well as the potential movement in price during this time period.
2. Please revise your disclosure throughout to clarify that the public offering price for each Gold Deposit Receipt will be based on the spot price for one troy ounce of Gold Bullion at the time of purchase.
Colleen Hennessy Vaulted Gold Bullion Trust June 9, 2016 Page 2
You may contact Shannon Sobotka, Staff Accountant, at (202) 551 -3856 or Daniel Gordon, Senior Assistant Chief Accountant, at (202) 551 -3486 if you have questions regarding comments on the financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202) 551 -8625 or me at (202) 551 -3466 with any other questions.
Sincerely,
/s/ Coy Garrison
Show Raw Text
Mail Stop 3233 June 9, 2016 Via E -mail Colleen Hennessy Bank of Montreal 111 West Monroe Street P. O. Box 755 Chicago, Illinois 60690 Re: Vaulted Gold Bullion Trust Registration Statement on Form S-1 Filed June 6, 2016 File No. 333-211858 Dear Ms. Hennessy: We have reviewed your amended registration statement and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not bel ieve an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. General 1. Please revise your disclosure to describe the risk that the execution price that an investor obtains could differ from the last price quote received. Please also revise your disclosure to discuss generally the expected time period between an investor placing an order and the trade being executed, as well as the potential movement in price during this time period. 2. Please revise your disclosure throughout to clarify that the public offering price for each Gold Deposit Receipt will be based on the spot price for one troy ounce of Gold Bullion at the time of purchase. Colleen Hennessy Vaulted Gold Bullion Trust June 9, 2016 Page 2 You may contact Shannon Sobotka, Staff Accountant, at (202) 551 -3856 or Daniel Gordon, Senior Assistant Chief Accountant, at (202) 551 -3486 if you have questions regarding comments on the financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202) 551 -8625 or me at (202) 551 -3466 with any other questions. Sincerely, /s/ Coy Garrison Coy Garrison Special Counsel Office of Real Estate and Commodities cc: Anna T. Pinedo, Esq. (via E -mail) Morrison & Foerster LLP