SEC Comment Letter for BANK OF MONTREAL (BMO) — Jul 17, 2018
BANK OF MONTREAL /CAN/ (BMO, BERZ, BNKD, BNKU, BULZ, CARD, CARU, DULL, FLYD, FLYU, FNGD, FNGO, FNGS, FNGU, GDXD, GDXU, JETD) (CIK 0000927971)
Date: July 17, 2018 · CIK: 0000927971 · Accession: 0000000000-18-021943
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File numbers found in text: 333-226132
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Mail Stop 3233 July 17, 2018 Via E -mail Darryl White Chief Executive Officer 100 King Street First Canadian Place Toronto, Ontario Canada M5X 1A1 Re: Vaulted Gold Bu llion Trust Registration Statement on Form S-1 Filed July 11, 2018 File No. 333-226132 Dear Mr. White : This is to advise you that we have not reviewed and will not review your registration statement . Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact me at (202) 551 -3391 with any questions. Sincerely, /s/ Erin E. Martin Erin E. Martin Legal Branch Chief Office of Real Estate and Commodities cc: Anna T. Pinedo, Esq. Mayer Brown LLP