Correspondence 0001193125-24-166859 from iSHARES TRUST (CIK 0001100663)
iSHARES TRUST (CIK 0001100663)
Date: June 24, 2024 · CIK: 0001100663 · Accession: 0001193125-24-166859
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. 2,726
Dear Ms. O’Neal:
This letter responds to your comments with respect to post-effective amendment (“PEA”) number 2,726 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 U.S. Manufacturing ETF (the “Fund”).
The Securities and Exchange Commission staff (the “Staff”) provided comments to the Trust on May 28, 2024. 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.
Comment 1: Please provide to the Staff a completed fee table and cost example at least five business days prior to the effective date of the registration statement.
Response: The Trust will provide to the Staff the Fund’s completed fee table and cost example.
Comment 2: Please include “Small Capitalization Risk” as a principal risk of the Fund.
Response: The Trust will add “Small-Capitalization Companies Risk” as a principal risk of investing in the Fund.
Comment 3: In the SAI, in the section entitled “Acceptance of Orders for Creation Units,” please delete the phrase “or have an adverse effect on the Fund or its shareholders (e.g., jeopardize the Fund’s tax status)” in prong (iv).
BRUSSELS CHICAGO FRANKFURT HOUSTON LONDON LOS ANGELES MILAN
NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON
Securities and Exchange Commission
June 24, 2024
Page
Response: The Trust respectfully submits that this disclosure has been discussed previously with the Staff and is consistent with prior comments received from David Orlic. We note that the current language reflects amendments from prior language that the Staff objected to and reflects additional conversations with the Staff in August 2022. (Please see the Trust’s letter filed with the Commission on August 26, 2022 in connection with PEA 2,549).
* * *
Sincerely,
/s/ Benjamin J. Haskin
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CORRESP 1 filename1.htm CORRESP 1875 K Street N.W. Washington, DC 20006-1238 Tel: 202 303 1000 Fax: 202 303 2000 June 24, 2024 VIA EDGAR Ms. Deborah O’Neal 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. 2,726 Dear Ms. O’Neal: This letter responds to your comments with respect to post-effective amendment (“PEA”) number 2,726 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 U.S. Manufacturing ETF (the “Fund”). The Securities and Exchange Commission staff (the “Staff”) provided comments to the Trust on May 28, 2024. 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. Comment 1: Please provide to the Staff a completed fee table and cost example at least five business days prior to the effective date of the registration statement. Response: The Trust will provide to the Staff the Fund’s completed fee table and cost example. Comment 2: Please include “Small Capitalization Risk” as a principal risk of the Fund. Response: The Trust will add “Small-Capitalization Companies Risk” as a principal risk of investing in the Fund. Comment 3: In the SAI, in the section entitled “Acceptance of Orders for Creation Units,” please delete the phrase “or have an adverse effect on the Fund or its shareholders (e.g., jeopardize the Fund’s tax status)” in prong (iv). BRUSSELS CHICAGO FRANKFURT HOUSTON LONDON LOS ANGELES MILAN NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON Securities and Exchange Commission June 24, 2024 Page 2 Response: The Trust respectfully submits that this disclosure has been discussed previously with the Staff and is consistent with prior comments received from David Orlic. We note that the current language reflects amendments from prior language that the Staff objected to and reflects additional conversations with the Staff in August 2022. (Please see the Trust’s letter filed with the Commission on August 26, 2022 in connection with PEA 2,549). * * * Sincerely, /s/ Benjamin J. Haskin Benjamin J. Haskin cc: Jennifer Kerslake Michael Gung George Rafal Luis Mora Toree Ho John Rupp - 2 -