Correspondence 0001193125-24-277148 from iSHARES TRUST (CIK 0001100663)
iSHARES TRUST (CIK 0001100663)
Date: Dec. 12, 2024 · CIK: 0001100663 · Accession: 0001193125-24-277148
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. 2,772
Dear Mr. Orlic:
This letter responds to your comments with respect to post-effective amendment (“PEA”) number 2,772 to the registration statement of the Trust filed pursuant to Rule 485(a) under the Securities Act of 1933 (“Securities Act”), on behalf of the following series of the Trust (the “Fund”):
iShares MSCI New Zealand ETF
The Securities and Exchange Commission staff (the “Staff”) provided comments to the Trust on December 3, 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:
The Staff notes that the Fund’s name changed from “iShares MSCI New Zealand Capped ETF” to “iShares MSCI New Zealand ETF.” Please confirm when this change occurred and if there were any filings that documented this change.
Response:
The name of the Fund changed from iShares MSCI New Zealand Capped ETF to iShares MSCI New Zealand ETF in a filing on December 26, 2017, effective December 29, 2017. The Trust notes that in connection with this name change, there were no material changes to the fund’s registration statement, including no material changes to the fund’s investment strategy.
Comment 2:
The Staff notes that on S-31, there is a placeholder for the broad-based benchmark included in the Fund’s “Performance Information” chart. Please provide the information for the broad-based benchmark.
BRUSSELS CHICAGO DALLAS FRANKFURT HOUSTON LONDON LOS ANGELES MILAN
MUNICH NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON
Securities and Exchange Commission
December 12, 2024
Page 2
Response:
The Trust confirms that the Fund will disclose the MSCI ACWI ex USA Index as the broad-based benchmark and will include its performance information.
* * *
Sincerely,
/s/ Anne C. Choe
Show Raw Text
CORRESP 1 filename1.htm CORRESP 1875 K Street, N.W. Washington, DC 20006-1238 Tel: 202 303 1000 Fax: 202 303 2000 December 12, 2024 VIA EDGAR Mr. David Orlic 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. 2,772 Dear Mr. Orlic: This letter responds to your comments with respect to post-effective amendment (“PEA”) number 2,772 to the registration statement of the Trust filed pursuant to Rule 485(a) under the Securities Act of 1933 (“Securities Act”), on behalf of the following series of the Trust (the “Fund”): iShares MSCI New Zealand ETF The Securities and Exchange Commission staff (the “Staff”) provided comments to the Trust on December 3, 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: The Staff notes that the Fund’s name changed from “iShares MSCI New Zealand Capped ETF” to “iShares MSCI New Zealand ETF.” Please confirm when this change occurred and if there were any filings that documented this change. Response: The name of the Fund changed from iShares MSCI New Zealand Capped ETF to iShares MSCI New Zealand ETF in a filing on December 26, 2017, effective December 29, 2017. The Trust notes that in connection with this name change, there were no material changes to the fund’s registration statement, including no material changes to the fund’s investment strategy. Comment 2: The Staff notes that on S-31, there is a placeholder for the broad-based benchmark included in the Fund’s “Performance Information” chart. Please provide the information for the broad-based benchmark. BRUSSELS CHICAGO DALLAS FRANKFURT HOUSTON LONDON LOS ANGELES MILAN MUNICH NEW YORK PALO ALTO PARIS ROME SAN FRANCISCO WASHINGTON Securities and Exchange Commission December 12, 2024 Page 2 Response: The Trust confirms that the Fund will disclose the MSCI ACWI ex USA Index as the broad-based benchmark and will include its performance information. * * * Sincerely, /s/ Anne C. Choe Anne C. Choe cc: Benjamin J. Haskin Marisa Rolland Michael Foland Michael Gung Toree Ho Luis Mora George Rafal Christiana Fahey - 2 -