Correspondence 0001104659-24-110454 from HC CAPITAL TRUST (CIK 0000934563)
HC CAPITAL TRUST (CIK 0000934563)
Date: Oct. 22, 2024 · CIK: 0000934563 · Accession: 0001104659-24-110454
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. 100
Dear Ms. Brutlag:
This correspondence is being provided to you in response to your comments (“Staff Comments”) communicated during our conversation of October 10, 2024 with respect to Post-Effective Amendment No. 100 to Registrant’s Registration Statement filed on August 28, 2024.
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 indicated that some Portfolios did not include an appropriate Broad-Based Index in their Tailored Shareholder Reports (“TSRs”).
October 22, 2024
Page 2
Response: Each Portfolio has added an appropriate Broad-Based Index to its performance disclosure and such indices were included in the prospectus as filed. Due to an oversight, some of these additional indices were omitted from the TSRs. They will be included in all TSRs going forward.
3. You noted that the Trust’s website did not include the most recent 1st and 3rd quarter holdings as required.
Response: Going forward, the Trust’s website will be updated to include the noted information as it is filed on Form N-PORT.
4. You requested that a parenthetical with The U.S. Equity Portfolio’s former name be included on page 2 of the prospectus.
Response: The disclosure will be revised as requested.
5. You requested that all Portfolios that had a turnover rate of over 100% for the prior year include “High Turnover Risk” as a principal risk.
Response: Registrant respectfully notes that none of the Trust’s Portfolios has experienced a turnover rate exceeding 100% in any of the past three fiscal years.
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 22,
2024
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. 100
Dear Ms. Brutlag:
This
correspondence is being provided to you in response to your comments (“Staff Comments”) communicated during our conversation
of October 10, 2024 with respect to Post-Effective Amendment No. 100 to Registrant’s Registration Statement filed on
August 28, 2024.
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 indicated that some Portfolios
did not include an appropriate Broad-Based Index in their Tailored Shareholder Reports (“TSRs”).
October 22, 2024
Page 2
Response: Each
Portfolio has added an appropriate Broad-Based Index to its performance disclosure and such
indices were included in the prospectus as filed. Due to an oversight, some of these additional
indices were omitted from the TSRs. They will be included in all TSRs going forward.
3. You noted that the Trust’s
website did not include the most recent 1st and 3rd quarter holdings
as required.
Response: Going forward, the Trust’s
website will be updated to include the noted information as it is filed on Form N-PORT.
4. You requested that a parenthetical
with The U.S. Equity Portfolio’s former name be included on page 2 of the prospectus.
Response: The disclosure will be revised
as requested.
5. You requested that all Portfolios
that had a turnover rate of over 100% for the prior year include “High Turnover Risk”
as a principal risk.
Response: Registrant respectfully notes
that none of the Trust’s Portfolios has experienced a turnover rate exceeding 100%
in any of the past three fiscal years.
Very truly yours,
Don E. Felice