Correspondence 0001104659-23-110339 from HC CAPITAL TRUST (CIK 0000934563)
HC CAPITAL TRUST (CIK 0000934563)
Date: Oct. 20, 2023 · CIK: 0000934563 · Accession: 0001104659-23-110339
AI Filing Summary & Sentiment
File numbers found in text: 811-08918
Letter
Division of Investment Management Washington, D.C. 20549 Re: HC Capital Trust (“Registrant”) File Nos.: 33-87762 and 811-08918 Post Effective Amendment No. 98
Dear Ms. Brutlag:
This correspondence is being provided to you in response to your comments (“Staff Comments”) communicated during our conversation of October 10, 2023 with respect to Post-Effective Amendment No. 98 to Registrant’s Registration Statement filed on August 28, 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 Registrant provide you with the completed updated fee and expense tables at least one week prior to effectiveness.
Response: The completed updated fee and expense tables have been provided under separate cover.
2. You requested a description of the circumstances surrounding the elimination of The Intermediate Term Municipal Bond II Portfolio.
October 20, 2023
Page 2
Response: The Intermediate Term Municipal Bond II Portfolio was reorganized into The Intermediate Term Municipal Bond Portfolio effective as of the close of business on June 23, 2023. At that time, all of the assets and liabilities of The Intermediate Term Municipal Bond II Portfolio were acquired by The Intermediate Term Municipal Bond Portfolio in exchange for shares of The Intermediate Term Municipal Bond Portfolio, which shares were then distributed to the shareholders of The Intermediate Term Municipal Bond II Portfolio. This reorganization was approved by a vote of the shareholders of The Intermediate Term Municipal Bond II Portfolio, pursuant to the proxy statement/prospectus filed on Form N-14 on April 28, 2023, at a shareholder meeting duly called and held on June 20, 2023. Following the reorganization, The Intermediate Term Municipal Bond II Portfolio was liquidated and the applicable EDGAR identifiers have been made inactive.
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
October 20, 2023
Ms. Samantha Brutlag
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
Post Effective Amendment No. 98
Dear Ms. Brutlag:
This correspondence is being provided to you in
response to your comments (“Staff Comments”) communicated during our conversation of October 10, 2023 with respect to Post-Effective
Amendment No. 98 to Registrant’s Registration Statement filed on August 28, 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 Registrant provide you with the completed
updated fee and expense tables at least one week prior to effectiveness.
Response:
The completed updated fee and expense tables have been provided under separate cover.
2. You requested a description of the circumstances surrounding the elimination of The Intermediate Term Municipal Bond II Portfolio.
October 20, 2023
Page 2
Response: The Intermediate Term Municipal Bond II Portfolio was reorganized into The Intermediate Term Municipal Bond Portfolio effective
as of the close of business on June 23, 2023. At that time, all of the assets and liabilities of The Intermediate Term Municipal Bond
II Portfolio were acquired by The Intermediate Term Municipal Bond Portfolio in exchange for shares of The Intermediate Term Municipal
Bond Portfolio, which shares were then distributed to the shareholders of The Intermediate Term Municipal Bond II Portfolio. This reorganization
was approved by a vote of the shareholders of The Intermediate Term Municipal Bond II Portfolio, pursuant to the proxy statement/prospectus
filed on Form N-14 on April 28, 2023, at a shareholder meeting duly called and held on June 20, 2023. Following the reorganization, The
Intermediate Term Municipal Bond II Portfolio was liquidated and the applicable EDGAR identifiers have been made inactive.
Very truly yours,
Don E. Felice