Correspondence 0001104659-23-045408 from HC CAPITAL TRUST (CIK 0000934563)
HC CAPITAL TRUST (CIK 0000934563)
Date: April 14, 2023 · CIK: 0000934563 · Accession: 0001104659-23-045408
AI Filing Summary & Sentiment
File numbers found in text: 811-08918
Letter
Via Edgar Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: HC Capital Trust (“Registrant”) File Nos.: 33-87762 and 811-08918
Dear Ms. McDonough and Mr. Orlic:
This correspondence is being provided to you in response to your comments communicated during two separate telephone conversations on March 29, 2023 and April 12, 2023 with respect to the Registrant’s filing on Form N-14 dated March 17, 2023.
For your convenience, we have summarized our understanding of the Staff Comments in bold typeface and set forth our response in the following italicized text.
1. You requested that the signature page include signatures from each of the Trust’s Principal Accounting Officer, Principal Financial Officer and Principal Executive Officer.
Response: The signatures will be included as requested.
2. In the Financial Highlights, you requested that the cross reference to “the Trust’s” prospectus be changed to refer to “the Acquiring Portfolio” and “the Target Portfolio.”
April 14, 2023
Page 2
Response: The disclosure will be revised as requested.
3. In the Expense Tables and Expense Examples, you requested that the Registrant confirm that the fees presented represent current fees.
Response: The fees presented in the final proxy prospectus will represent current fees.
4. You requested that the performance information presented in the proxy prospectus fully comply with Form N-1A performance parameters, including benchmarks, bar chart and lead in language.
Response: The disclosure will be revised as requested.
5. You requested that the proxy prospectus disclose whether the allocation of costs will differ if the reorganization is not approved.
Response: The disclosure will be revised as requested.
6. You requested confirmation that there had been no material changes to the information in the Capitalization tables and inquired as to whether there should be an adjustment for shares outstanding.
Response: The Capitalization tables will be updated to show information as of March 28, 2023. An adjustment for shares outstanding has been added.
7. You requested that a copy of the tax opinion be included in the 485(b) filing.
Response: The tax opinion will be filed as requested.
Very truly yours,
Don E. Felice
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Stradley Ronon Stevens & Young, LLP
Suite 2600
2005 Market Street
Philadelphia, PA 19103-7018
Telephone 215.564.8000
Fax 215.564.8120
www.stradley.com
Don E. Felice
dfelice@stradley.com
(215) 564-8794
April 14, 2023
Via Edgar
Ms. Melissa McDonough
Mr. David Orlic
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Re: HC Capital Trust (“Registrant”)
File Nos.: 33-87762 and 811-08918
Dear Ms. McDonough and Mr. Orlic:
This correspondence is being provided to you
in response to your comments communicated during two separate telephone conversations on March 29, 2023 and April 12, 2023
with respect to the Registrant’s filing on Form N-14 dated March 17, 2023.
For your convenience, we have summarized our
understanding of the Staff Comments in bold typeface and set forth our response in the following italicized text.
1. You requested that the signature
page include signatures from each of the Trust’s Principal Accounting Officer,
Principal Financial Officer and Principal Executive Officer.
Response: The signatures will be included as
requested.
2. In the Financial Highlights, you
requested that the cross reference to “the Trust’s” prospectus be changed
to refer to “the Acquiring Portfolio” and “the Target Portfolio.”
April 14, 2023
Page 2
Response: The disclosure will be revised as requested.
3. In the Expense Tables and Expense
Examples, you requested that the Registrant confirm that the fees presented represent current
fees.
Response: The fees presented in the final proxy
prospectus will represent current fees.
4. You requested that the performance
information presented in the proxy prospectus fully comply with Form N-1A performance
parameters, including benchmarks, bar chart and lead in language.
Response: The disclosure will be revised as requested.
5. You requested that the proxy prospectus
disclose whether the allocation of costs will differ if the reorganization is not approved.
Response: The disclosure will be revised as requested.
6. You requested confirmation that there
had been no material changes to the information in the Capitalization tables and inquired
as to whether there should be an adjustment for shares outstanding.
Response: The Capitalization tables will be updated
to show information as of March 28, 2023. An adjustment for shares outstanding has been
added.
7. You requested that a copy of the
tax opinion be included in the 485(b) filing.
Response: The tax opinion will be filed as requested.
Very truly yours,
Don E. Felice