SEC Company Response from AIM COUNSELOR SERIES TRUST (INVESCO COUNSELOR SERIES TRUST) (CIK 0001112996) — Feb 20, 2020
AIM COUNSELOR SERIES TRUST (INVESCO COUNSELOR SERIES TRUST) (CIK 0001112996)
Date: Feb. 20, 2020 · CIK: 0001112996 · Accession: 0001193125-20-043602
AI Filing Summary & Sentiment
File numbers found in text: 333-236069
Letter
[Invesco Letterhead]
11 Greenway Plaza
Suite 1000
Houston, TX 77046
February 20, 2020
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
100 F Street NE
Washington, DC 20549
Re: AIM Counselor Series Trust (Invesco Counselor Series Trust)
CIK No. 0001112996; File No. 333-236069
Ladies and Gentlemen:
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, AIM Counselor Series Trust (Invesco Counselor Series Trust) (the “Registrant”) and Invesco Distributors, Inc., the distributor of the Registrant’s shares, hereby request acceleration of the effective date of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-14 (File No. 333-236069) so that such Registration Statement may be declared effective on February 24, 2020, or as soon as practicable thereafter.
The Registrant hereby acknowledges that: (1) should the Securities and Exchange Commission (the “Commission”) or its staff (“Staff”), acting pursuant to delegated authority, declare the above-referenced registration statement effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filing and the Staff’s comments, the Registrant’s changes to the disclosure in response to the Staff’s comments or the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, do not relieve the Registrant of this responsibility; and (3) the Registrant may not assert this action or the Staff’s comments as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States.
Please contact Kenneth L. Greenberg, Esq. of Stradley Ronon at (215) 564-8149 with respect to this acceleration request or in his absence, contact me at (404) 493-3463.
Very truly yours,
AIM Counselor Series Trust (Invesco Counselor Series Trust)
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CORRESP 1 filename1.htm CORRESP [Invesco Letterhead] 11 Greenway Plaza Suite 1000 Houston, TX 77046 February 20, 2020 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management Disclosure Review and Accounting Office 100 F Street NE Washington, DC 20549 Re: AIM Counselor Series Trust (Invesco Counselor Series Trust) CIK No. 0001112996; File No. 333-236069 Ladies and Gentlemen: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, AIM Counselor Series Trust (Invesco Counselor Series Trust) (the “Registrant”) and Invesco Distributors, Inc., the distributor of the Registrant’s shares, hereby request acceleration of the effective date of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-14 (File No. 333-236069) so that such Registration Statement may be declared effective on February 24, 2020, or as soon as practicable thereafter. The Registrant hereby acknowledges that: (1) should the Securities and Exchange Commission (the “Commission”) or its staff (“Staff”), acting pursuant to delegated authority, declare the above-referenced registration statement effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filing and the Staff’s comments, the Registrant’s changes to the disclosure in response to the Staff’s comments or the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, do not relieve the Registrant of this responsibility; and (3) the Registrant may not assert this action or the Staff’s comments as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States. Please contact Kenneth L. Greenberg, Esq. of Stradley Ronon at (215) 564-8149 with respect to this acceleration request or in his absence, contact me at (404) 493-3463. Very truly yours, AIM Counselor Series Trust (Invesco Counselor Series Trust) /s/ Jeffrey H. Kupor Jeffrey H. Kupor, Esq. Senior Vice President Chief Legal Officer Secretary Invesco Distributors, Inc. /s/ Jeffrey H. Kupor Jeffrey H. Kupor, Esq. Senior Vice President and Secretary cc: Jaea Hahn