Correspondence 0000894189-25-004498 from KINETICS PORTFOLIOS TRUST (CIK 0001113229)
KINETICS PORTFOLIOS TRUST (CIK 0001113229)
Date: June 17, 2025 · CIK: 0001113229 · Accession: 0000894189-25-004498
AI Filing Summary & Sentiment
File numbers found in text: 811-09923
Letter
Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Kinetics Portfolios Trust (the “Trust”) File No. 811-09923
Dear Ms. Brutlag:
This correspondence responds to a comment that the Trust received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) on June 9, 2025, with respect to Amendment No. 44 to the Trust’s Registration Statement on Form N-1A filed May 8, 2025 (the “Amendment”) with respect to each of its series (each a “Portfolio,” together the “Portfolios”). For your convenience, the comment has been reproduced with a response following the comment. Capitalized terms not otherwise defined have the same meaning as in the Amendment.
Prospectus
Comment 1.Discussion regarding the Secured Overnight Financing Rate (“SOFR Risk”) on page 66 of the Prospectus should generally be updated and revised given the discontinuation of LIBOR and history of SOFR.
Response: The Trust undertakes to make clarifying changes to this disclosure in the next POS AMI filing.
* * *
If you have any questions regarding the above response, please do not hesitate to contact Chad Fickett at (608) 716-8890 or chad.fickett@usbank.com.
Sincerely,
/s/ Jay Kesslen
Show Raw Text
CORRESP 1 filename1.htm Document Kinetics Portfolios Trust 615 East Michigan Street | Milwaukee, Wisconsin 53202 June 17, 2025 Ms. Samantha Brutlag U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Kinetics Portfolios Trust (the “Trust”) File No. 811-09923 Dear Ms. Brutlag: This correspondence responds to a comment that the Trust received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) on June 9, 2025, with respect to Amendment No. 44 to the Trust’s Registration Statement on Form N-1A filed May 8, 2025 (the “Amendment”) with respect to each of its series (each a “Portfolio,” together the “Portfolios”). For your convenience, the comment has been reproduced with a response following the comment. Capitalized terms not otherwise defined have the same meaning as in the Amendment. Prospectus Comment 1.Discussion regarding the Secured Overnight Financing Rate (“SOFR Risk”) on page 66 of the Prospectus should generally be updated and revised given the discontinuation of LIBOR and history of SOFR. Response: The Trust undertakes to make clarifying changes to this disclosure in the next POS AMI filing. * * * If you have any questions regarding the above response, please do not hesitate to contact Chad Fickett at (608) 716-8890 or chad.fickett@usbank.com. Sincerely, /s/ Jay Kesslen Jay Kesslen Assistant Secretary and Vice President of the Trust and the Company