Correspondence 0000894189-23-005513 from ADVISORS SERIES TRUST (CIK 0001027596)
ADVISORS SERIES TRUST (CIK 0001027596)
Date: Aug. 10, 2023 · CIK: 0001027596 · Accession: 0000894189-23-005513
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-17391, 811-07959
Letter
Division of Investment Management Advisors Series Trust (the “Trust”) File Nos.: 333-17391 and 811-07959 Semper MBS Total Return Fund (S000041568) Semper Short Duration Fund (S000044807)
Dear Ms. O’Neal:
This correspondence is being filed in response to an additional comment the Trust received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on August 10, 2023, regarding the Trust’s Preliminary Proxy Statement filed July 28, 2023 (SEC Accession No. 0000894189-23-005177) and the Trust’s response letter filed August 9, 2023 (SEC Accession No.0000894189-23-005478). The Staff’s comment is summarized in bold font below followed by the Trust’s response. Capitalized terms not otherwise defined have the same meaning as in the Preliminary Proxy Statement.
Comment: If applicable, please state supplementally that no unfair burden will be imposed on the Funds as a result of the Transition.
Response: The Trust represents that no unfair burden will be imposed on the Funds as a result of the Transition. As noted in the previous response letter and as disclosed in the Preliminary Proxy Statement, neither the management fees, nor the expense caps will change as a result of the Transition. The Trust has entered into an Operating Expenses Limitation Agreement with Medalist Capitalist, under which the expense caps will remain in place for a minimum of two years following the Transition.
If you have any questions regarding the above response, please do not hesitate to contact the undersigned at (626) 914-7363 or at elaine.richards@usbank.com.
Very truly yours,
/s/ Elaine Richards
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CORRESP 1 filename1.htm Document Advisors Series Trust c/o U.S. Bank Global Fund Services 2020 East Financial Way, Suite 100 Glendora, California 91741 August 10, 2023 Ms. Deborah O’Neal U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Advisors Series Trust (the “Trust”) File Nos.: 333-17391 and 811-07959 Semper MBS Total Return Fund (S000041568) Semper Short Duration Fund (S000044807) Dear Ms. O’Neal: This correspondence is being filed in response to an additional comment the Trust received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on August 10, 2023, regarding the Trust’s Preliminary Proxy Statement filed July 28, 2023 (SEC Accession No. 0000894189-23-005177) and the Trust’s response letter filed August 9, 2023 (SEC Accession No.0000894189-23-005478). The Staff’s comment is summarized in bold font below followed by the Trust’s response. Capitalized terms not otherwise defined have the same meaning as in the Preliminary Proxy Statement. Comment: If applicable, please state supplementally that no unfair burden will be imposed on the Funds as a result of the Transition. Response: The Trust represents that no unfair burden will be imposed on the Funds as a result of the Transition. As noted in the previous response letter and as disclosed in the Preliminary Proxy Statement, neither the management fees, nor the expense caps will change as a result of the Transition. The Trust has entered into an Operating Expenses Limitation Agreement with Medalist Capitalist, under which the expense caps will remain in place for a minimum of two years following the Transition. If you have any questions regarding the above response, please do not hesitate to contact the undersigned at (626) 914-7363 or at elaine.richards@usbank.com. Very truly yours, /s/ Elaine Richards Elaine E. Richards Secretary Advisors Series Trust 1