SEC Company Response from TRUST FOR PROFESSIONAL MANAGERS (CIK 0001141819) — Sep 12, 2025
TRUST FOR PROFESSIONAL MANAGERS (CIK 0001141819)
Date: Sept. 12, 2025 · CIK: 0001141819 · Accession: 0000894189-25-006916
AI Filing Summary & Sentiment
File numbers found in text: 333-62298, 811-10401
Letter
VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management Washington, D.C. 20549 RE: Trust for Professional Managers (the “Trust”) Securities Act Registration No: 333-62298 Investment Company Registration No: 811-10401
Dear Mr. Ellington,
This correspondence is being filed in response to the oral comments provided to Jay S. Fitton, Secretary of the Trust, on September 3, 2025 regarding your review of the recent shareholder reports filed on Form N-CSR and Form N-CEN for series of the Trust (each, a “Fund,” and collectively, the “Funds”) listed below. For your convenience in reviewing the Trust’s responses, your comments are included in bold typeface immediately followed by the Trust’s responses.
S000067414 Jensen Global Quality Growth Fund
S000028264 Jensen Quality Mid Cap Fund
S000085931 Jensen Quality Growth ETF
The Trust’s responses to your comments are as follows:
1.Comment: The Staff notes that as of May 31, 2025, the Jensen Quality Growth ETF and the Jensen Global Quality Growth Fund had 37.9% and 41.2%, respectively, of each Fund’s net assets invested in the information technology sector. The Staff further notes that the respective Funds do not disclose emphasizing investments in the information technology sector in their principal investment strategies or have an “Information Technology Sector Risk” as a principal investment risk in the prospectuses. Accordingly, the Staff suggests the respective Funds consider revising their principal investment strategies and principal risks to include disclosure related to investments in the information technology sector during the Funds’ next annual update of the prospectuses.
Response: The Trust will undertake to revise the principal investment strategies and principal risks disclosure for each respective Fund to include the information technology sector and a related risk during the Funds’ next annual update of the prospectuses for the fiscal year ended May 31, 2025.
2.Comment: The Staff notes that the Jensen Global Quality Growth Fund is identified in the prospectus as non-diversified, but it appears that the Fund is operating as diversified. If the Fund has been operating as diversified for more than three years, please confirm shareholder approval will be obtained prior to the Fund’s status being changed back to non-diversified (see Section 13(a)(1) of the Investment Company Act of 1940, as amended, and Rule 13a-1).
Response: The Trust responds by confirming that as of the date of this response, the Jensen Global Quality Growth Fund has not been operating as diversified for more than three years. If the Fund continues operating as diversified for more than three years, the Fund will obtain shareholder approval prior to changing the Fund’s status back to non-diversified.
* * * * * *
If you have any additional questions or require further information, please contact Jay Fitton at (513) 520-5925.
Sincerely,
/s/ Jennifer A. Lima
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CORRESP 1 filename1.htm Document Trust for Professional Managers c/o U.S. Bank Global Fund Services 615 East Michigan Street Milwaukee, Wisconsin 53202 September 12, 2025 VIA EDGAR TRANSMISSION Mr. Kenneth Ellington United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 RE: Trust for Professional Managers (the “Trust”) Securities Act Registration No: 333-62298 Investment Company Registration No: 811-10401 Dear Mr. Ellington, This correspondence is being filed in response to the oral comments provided to Jay S. Fitton, Secretary of the Trust, on September 3, 2025 regarding your review of the recent shareholder reports filed on Form N-CSR and Form N-CEN for series of the Trust (each, a “Fund,” and collectively, the “Funds”) listed below. For your convenience in reviewing the Trust’s responses, your comments are included in bold typeface immediately followed by the Trust’s responses. S000067414 Jensen Global Quality Growth Fund S000028264 Jensen Quality Mid Cap Fund S000085931 Jensen Quality Growth ETF The Trust’s responses to your comments are as follows: 1.Comment: The Staff notes that as of May 31, 2025, the Jensen Quality Growth ETF and the Jensen Global Quality Growth Fund had 37.9% and 41.2%, respectively, of each Fund’s net assets invested in the information technology sector. The Staff further notes that the respective Funds do not disclose emphasizing investments in the information technology sector in their principal investment strategies or have an “Information Technology Sector Risk” as a principal investment risk in the prospectuses. Accordingly, the Staff suggests the respective Funds consider revising their principal investment strategies and principal risks to include disclosure related to investments in the information technology sector during the Funds’ next annual update of the prospectuses. Response: The Trust will undertake to revise the principal investment strategies and principal risks disclosure for each respective Fund to include the information technology sector and a related risk during the Funds’ next annual update of the prospectuses for the fiscal year ended May 31, 2025. 2.Comment: The Staff notes that the Jensen Global Quality Growth Fund is identified in the prospectus as non-diversified, but it appears that the Fund is operating as diversified. If the Fund has been operating as diversified for more than three years, please confirm shareholder approval will be obtained prior to the Fund’s status being changed back to non-diversified (see Section 13(a)(1) of the Investment Company Act of 1940, as amended, and Rule 13a-1). Response: The Trust responds by confirming that as of the date of this response, the Jensen Global Quality Growth Fund has not been operating as diversified for more than three years. If the Fund continues operating as diversified for more than three years, the Fund will obtain shareholder approval prior to changing the Fund’s status back to non-diversified. * * * * * * If you have any additional questions or require further information, please contact Jay Fitton at (513) 520-5925. Sincerely, /s/ Jennifer A. Lima Jennifer A. Lima President Trust for Professional Managers