SEC Company Response from iSHARES TRUST (CIK 0001100663) — Feb 21, 2020
iSHARES TRUST (CIK 0001100663)
Date: Feb. 21, 2020 · CIK: 0001100663 · Accession: 0001193125-20-044870
AI Filing Summary & Sentiment
File numbers found in text: 333-92935, 811-09729
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Re: iShares Trust (the “Trust”) (Securities Act File No. 333-92935 and Investment Company Act File No. 811-09729) Post-Effective Amendment No. 2,247
Dear Ms. O’Neal-Johnson:
This letter responds to your comments with respect to post-effective amendment (“PEA”) number 2,247 to the registration statement of the Trust filed pursuant to Rule 485(a) under the Securities Act of 1933 (“Securities Act”) on behalf of iShares J.P. Morgan USD Emerging Market Bond ETF and iShares Core International Aggregate Bond ETF, each a series of the Trust (each a “Fund”).
The Securities and Exchange Commission (the “Commission”) staff (the “Staff”) provided comments to the Trust on February 3, 2020. For your convenience, the Staff’s comments are summarized below and each comment is followed by the Trust’s response. Capitalized terms have the meanings assigned in the Fund’s prospectus unless otherwise defined in this letter and each comment applies to both Funds unless the comment indicates otherwise.
Comment 1:
Please disclose the number of bonds in the underlying index or an expected range of bonds in the index.
Response:
Each Fund respectfully notes that the number of component securities is listed in the Fund’s Statement of Additional Information in the section entitled “Construction and Maintenance of the Underlying Indexes.”
Comment 2:
For iShares J.P. Morgan USD Emerging Market Bond ETF, please add disclosure that the Fund may invest in “junk bonds.”
Securities and Exchange Commission
February 21, 2020
Page
Response:
The Fund has added disclosure to that effect.
Comment 3:
Consistent with ADI 2019-08, please order the summary of principal risks based on those risks that that are reasonably likely to adversely affect the Fund’s net asset value, yield, and total return.
Response:
The Trust is reviewing the guidance from the Division of Investment Management internally. Additionally, the Trust respectfully notes the following language currently in the sections entitled “Fund Overview - Summary of Principal Risks,” “A Further Discussion of Principal Risks” and “A Further Discussion of Other Risks”:
“The order of the below risk factors does not indicate the significance of any particular risk factor.”
Comment 4:
For iShares Core International Aggregate Bond ETF, please confirm to the Staff the percentage of issuers located outside of the U.S.
Response:
The Trust represents that approximately 97% of the market value of bonds in the Underlying Index is represented by bonds that were issued outside of the U.S. or by non-U.S. issuers.
****
Sincerely,
/s/ Benjamin J. Haskin
Show Raw Text
CORRESP 1 filename1.htm SEC Comment Response Letter 1875 K Street N.W. Washington, DC 20006-1238 Tel: 202 303 1000 Fax: 202 303 2000 February 21, 2020 VIA EDGAR Ms. Deborah O’Neal-Johnson Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: iShares Trust (the “Trust”) (Securities Act File No. 333-92935 and Investment Company Act File No. 811-09729) Post-Effective Amendment No. 2,247 Dear Ms. O’Neal-Johnson: This letter responds to your comments with respect to post-effective amendment (“PEA”) number 2,247 to the registration statement of the Trust filed pursuant to Rule 485(a) under the Securities Act of 1933 (“Securities Act”) on behalf of iShares J.P. Morgan USD Emerging Market Bond ETF and iShares Core International Aggregate Bond ETF, each a series of the Trust (each a “Fund”). The Securities and Exchange Commission (the “Commission”) staff (the “Staff”) provided comments to the Trust on February 3, 2020. For your convenience, the Staff’s comments are summarized below and each comment is followed by the Trust’s response. Capitalized terms have the meanings assigned in the Fund’s prospectus unless otherwise defined in this letter and each comment applies to both Funds unless the comment indicates otherwise. Comment 1: Please disclose the number of bonds in the underlying index or an expected range of bonds in the index. Response: Each Fund respectfully notes that the number of component securities is listed in the Fund’s Statement of Additional Information in the section entitled “Construction and Maintenance of the Underlying Indexes.” Comment 2: For iShares J.P. Morgan USD Emerging Market Bond ETF, please add disclosure that the Fund may invest in “junk bonds.” Securities and Exchange Commission February 21, 2020 Page 2 Response: The Fund has added disclosure to that effect. Comment 3: Consistent with ADI 2019-08, please order the summary of principal risks based on those risks that that are reasonably likely to adversely affect the Fund’s net asset value, yield, and total return. Response: The Trust is reviewing the guidance from the Division of Investment Management internally. Additionally, the Trust respectfully notes the following language currently in the sections entitled “Fund Overview - Summary of Principal Risks,” “A Further Discussion of Principal Risks” and “A Further Discussion of Other Risks”: “The order of the below risk factors does not indicate the significance of any particular risk factor.” Comment 4: For iShares Core International Aggregate Bond ETF, please confirm to the Staff the percentage of issuers located outside of the U.S. Response: The Trust represents that approximately 97% of the market value of bonds in the Underlying Index is represented by bonds that were issued outside of the U.S. or by non-U.S. issuers. **** Sincerely, /s/ Benjamin J. Haskin Benjamin J. Haskin cc: Deepa Damre Nadia Persaud Anne Choe Michael Gung George Rafal Jamie Hahn - 2 -