Correspondence 0001193125-24-012157 from VIRTUS ASSET TRUST (CIK 0001018593)
VIRTUS ASSET TRUST (CIK 0001018593)
Date: Jan. 22, 2024 · CIK: 0001018593 · Accession: 0001193125-24-012157
AI Filing Summary & Sentiment
File numbers found in text: 333-275759, 333-275760
Letter
One International Place
40th Floor
100 Oliver Street
Boston, MA 02110-2605
+1 617 728 7100 Main
+1 617 426 6567 Fax
www.dechert.com
January 22, 2024
Securities and Exchange Commission
100 F Street, NE
STEPHANIE A. CAPISTRON
STEPHANIE.CAPISTRON@DECHERT.COM
+1 617 728 7127 DIRECT
Washington, D.C. 20549
Attention: Michael Rosenberg
Re: Virtus Asset Trust (the “Registrant”)
(File Nos. 333-275759 and 333-275760)
Mr. Rosenberg:
This letter responds to the comment provided by the SEC staff via email on January 19, 2024 with respect to the review of the Registration Statements filed on Form N-14 under the Securities Act of 1933, as amended, in connection with (1) the reorganization of Virtus Seix High Yield Income Fund, a series of Virtus Strategy Trust, and Virtus Seix High Income Fund, a series of the Registrant, with and into Virtus Seix High Yield Fund, also a series of the Registrant, and (2) the reorganization of Virtus Seix Ultra-Short Bond Fund, a series of the Registrant, with and into Virtus Seix U.S. Government Securities Ultra-Short Bond Fund, also a series of the Registrant. We have reproduced your comment below, followed by the Registrant’s response. Capitalized terms have the meanings attributed to such terms in the Registration Statements.
Comment 1. Please supplementally explain the nature of the extraordinary proxy expenses disclosed in the fee table footnotes and why they are not reflected in the table. Please also disclose in the footnote the Total Annual Fund Operating Expenses before expense reimbursement if such amounts were reflected.
Response 1. The Registrant has confirmed that there were no extraordinary proxy expenses incurred during the period covered in the fee tables. Accordingly, there were no such expenses excluded from the fee tables and the referenced footnotes have been deleted.
* * *
We believe that the foregoing has been responsive to the Staff’s comment. Please call the undersigned at (617) 728-7127 if you wish to discuss this correspondence further.
Very truly yours,
/s/ Stephanie A. Capistron
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CORRESP 1 filename1.htm CORRESP One International Place 40th Floor 100 Oliver Street Boston, MA 02110-2605 +1 617 728 7100 Main +1 617 426 6567 Fax www.dechert.com January 22, 2024 Securities and Exchange Commission 100 F Street, NE STEPHANIE A. CAPISTRON STEPHANIE.CAPISTRON@DECHERT.COM +1 617 728 7127 DIRECT Washington, D.C. 20549 Attention: Michael Rosenberg Re: Virtus Asset Trust (the “Registrant”) (File Nos. 333-275759 and 333-275760) Mr. Rosenberg: This letter responds to the comment provided by the SEC staff via email on January 19, 2024 with respect to the review of the Registration Statements filed on Form N-14 under the Securities Act of 1933, as amended, in connection with (1) the reorganization of Virtus Seix High Yield Income Fund, a series of Virtus Strategy Trust, and Virtus Seix High Income Fund, a series of the Registrant, with and into Virtus Seix High Yield Fund, also a series of the Registrant, and (2) the reorganization of Virtus Seix Ultra-Short Bond Fund, a series of the Registrant, with and into Virtus Seix U.S. Government Securities Ultra-Short Bond Fund, also a series of the Registrant. We have reproduced your comment below, followed by the Registrant’s response. Capitalized terms have the meanings attributed to such terms in the Registration Statements. Comment 1. Please supplementally explain the nature of the extraordinary proxy expenses disclosed in the fee table footnotes and why they are not reflected in the table. Please also disclose in the footnote the Total Annual Fund Operating Expenses before expense reimbursement if such amounts were reflected. Response 1. The Registrant has confirmed that there were no extraordinary proxy expenses incurred during the period covered in the fee tables. Accordingly, there were no such expenses excluded from the fee tables and the referenced footnotes have been deleted. * * * We believe that the foregoing has been responsive to the Staff’s comment. Please call the undersigned at (617) 728-7127 if you wish to discuss this correspondence further. Very truly yours, /s/ Stephanie A. Capistron Stephanie A. Capistron 1