SEC Comment Letter for GLOBAL MACRO TRUST (CIK 0001145765) — Mar 9, 2021
GLOBAL MACRO TRUST (CIK 0001145765)
Date: March 9, 2021 · CIK: 0001145765 · Accession: 0000000000-21-002826
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File numbers found in text: 333-229651
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United States securities and exchange commission logo
March 9, 2021
Steven Felsenthal
General Counsel and Chief Compliance Officer
Millburn Ridgefield Corporation
55 West 46th Street, 31st Floor
New York, NY 10036
Re:Global Macro Trust
Post-Effective Amendment No. 2 to
Registration Statement on Form S-1
Filed February 12, 2021
File No. 333-229651
Dear Mr. Felsenthal:
We have reviewed your post-effective amendment and have the following comments. In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Post-Effective Amendment No. 2 to Registration Statement on Form S-1
The Risks You Face
General, page 8
1.We note that the Trust appears to invest in futures contracts in the ordinary course of
business. Please revise to disclose the material risks related to investing in futures
contracts.
Virtual Currency Futures may be Volatile and may Become Illiquid, page 9
2.We note that you have added risk factor disclosure that the "Trust may trade virtual
currency futures (e.g., futures contracts on Bitcoin or Ether)." Please expand your
disclosure, either here or elsewhere in your filing, to address the following:
FirstName LastNameSteven Felsenthal
Comapany NameMillburn Ridgefield Corporation
March 9, 2021 Page 2
FirstName LastName
Steven Felsenthal
Millburn Ridgefield Corporation
March 9, 2021
Page 2
•disclose in greater detail your plans to trade digital asset futures, including whether
such futures will be material to the Trust's operations or financial condition and
whether the Trust has limitations or restrictions on trading digital asset futures;
•explicitly identify any digital asset futures other than Bitcoin or Ether that the Trust
may trade, or, if applicable, clarify that the digital asset futures are limited to Bitcoin
and Ether;
•describe in greater detail the liquidity and trading characteristics of the digital asset
futures that you may trade; and
•if there are material risks unique to trading futures contracts on Bitcoin or Ether, or
other digital asset futures that the Trust may trade, please include them here or as
separate risks.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact David Lin, Staff Attorney, at (202) 551-3552 or Sandra Hunter
Berkheimer, Legal Branch Chief, at (202) 551-3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance