Correspondence 0001580642-25-003045 from UNIFIED SERIES TRUST (CIK 0001199046)
UNIFIED SERIES TRUST (CIK 0001199046)
Date: May 9, 2025 · CIK: 0001199046 · Accession: 0001580642-25-003045
AI Filing Summary & Sentiment
File numbers found in text: 811-21237
Letter
Division of Investment Management New York, NY 10004-2616 Attention: Ms. Mindy Rotter, Esq., CPA Re: Unified Series Trust (the “Registrant”) SEC File No. 811-21237 Sarbanes Oxley Review
Dear Ms. Rotter:
On April 23, 2025, you indicated that the Securities and Exchange Commission Staff had completed its routine review of the Registrant’s financial statements for fiscal years ended August 31, 2024, September 30, 2024, and December 31, 2024, as required under the Sarbanes Oxley Act of 2002. The list of Funds reviewed is included in this letter as Exhibit A. You confirmed that the Staff had three comments with respect to the series reviewed. Below are the Staff’s comments and Registrant’s responses.
With respect to the Fisher, Tactical, Ballast and Channel Funds:
Comment: The Staff noted that the response to Item 11 in each Fund’s Form N-CSR indicates that the information is included under Item 7 of the Form N-CSR. Explain where in Item 7 this information is included and how it meets the disclosure requirements.
Response: Item 11 requires a statement regarding the basis for approval of the investment advisory contract. If the renewal occurred during the semi-annual reporting period, or the last six months of the annual reporting period, the information is included under the heading “Management Agreement Renewal of Item 7.” As a general matter, the management agreement renewal language is included in Item 7 when it is required to be included.
With respect to the Appleseed and Tactical Funds:
Comment: Confirm how each non-diversified fund continues to maintain non-diversified status. If any fund has been operating as diversified for more than three years, shareholder approval is required to return to non-diversified status.
Response:
With respect to the Appleseed Fund, the Fund has been non-diversified for several periods during the past three years. The Fund’s diversification status is being monitored closely, and if the Fund remains
diversified continuously for three years, the Fund’s registration statement and related disclosures will be updated appropriately and the Fund will not operate as non-diversified without shareholder approval.
With respect to the Tactical Fund, the Fund has not operated as non-diversified but has a single shareholder who has provided written consent to return to non-diversified status prior to the expiration of three years.
With respect to the Crawford Multi-Asset Income Fund:
Comment: The Schedule of Investments includes a footnote (b) under Money Maret Funds. The Staff is unable to find where this reference is explained.
Response: The Registrant confirms the footnote (b) was inadvertently excluded from the page and confirms it will be included in future reports.
Thank you for your review. If you have any additional questions, or need additional information, please contact me at 513-346-3324.
Sincerely,
/s/ Elisabeth Dahl
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UNIFIED SERIES TRUST
225 Pictoria Drive, Suite 450
Cincinnati, OH 45246
May 9, 2025
Division of Investment Management
Disclosure Review and Accounting Office
U.S. Securities and Exchange Commission
New York Regional Office
100 Pearl Street, Suite 20-100
New York, NY 10004-2616
Attention: Ms. Mindy Rotter, Esq., CPA
Re: Unified Series Trust (the “Registrant”) SEC File No. 811-21237
Sarbanes Oxley Review
Dear Ms. Rotter:
On April 23, 2025, you indicated that the Securities and Exchange Commission
Staff had completed its routine review of the Registrant’s financial statements for fiscal years ended August 31, 2024, September
30, 2024, and December 31, 2024, as required under the Sarbanes Oxley Act of 2002. The list of Funds reviewed is included in this letter
as Exhibit A. You confirmed that the Staff had three comments with respect to the series reviewed. Below are the Staff’s comments
and Registrant’s responses.
With respect to the Fisher, Tactical, Ballast and Channel Funds:
Comment: The Staff noted that the response to Item 11 in each Fund’s
Form N-CSR indicates that the information is included under Item 7 of the Form N-CSR. Explain where in Item 7 this information is included
and how it meets the disclosure requirements.
Response: Item 11 requires a statement regarding the basis for approval
of the investment advisory contract. If the renewal occurred during the semi-annual reporting period, or the last six months of the annual
reporting period, the information is included under the heading “Management Agreement Renewal of Item 7.” As a general matter,
the management agreement renewal language is included in Item 7 when it is required to be included.
With respect to the Appleseed and Tactical Funds:
Comment: Confirm how each non-diversified fund continues to maintain
non-diversified status. If any fund has been operating as diversified for more than three years, shareholder approval is required to return
to non-diversified status.
Response:
With respect to the Appleseed Fund, the
Fund has been non-diversified for several periods during the past three years. The Fund’s diversification status is being monitored
closely, and if the Fund remains
diversified
continuously for three years, the Fund’s registration statement and related disclosures will be updated appropriately and the Fund
will not operate as non-diversified without shareholder approval.
With respect to the Tactical Fund, the Fund has not operated as non-diversified
but has a single shareholder who has provided written consent to return to non-diversified status prior to the expiration of three years.
With respect to the Crawford Multi-Asset Income Fund:
Comment: The Schedule of Investments includes a footnote (b) under
Money Maret Funds. The Staff is unable to find where this reference is explained.
Response: The Registrant confirms the footnote (b) was inadvertently
excluded from the page and confirms it will be included in future reports.
Thank you for your review. If you have any additional questions, or need
additional information, please contact me at 513-346-3324.
Sincerely,
/s/ Elisabeth Dahl
Elisabeth Dahl
Secretary, Unified Series Trust
Copy to: Mr. Martin Dean, President, Unified Series Trust
Mr. Zachary Richmond, Treasurer and Chief
Financial Officer, Unified Series Trust
Ms. JoAnn Strasser, Esq., Thompson Hine LLP
Exhibit A
Complex Count
Series ID
FYE
Series Name
1
S000014625
9/30/2024
Appleseed Fund
2
S000070046
9/30/2024
BALLAST SMALL/MID CAP ETF
3
S000002756
9/30/2024
Channel Income Fund (formerly, Channel Short Duration Income Fund)
4
S000000534
12/31/2024
Crawford Large Cap Dividend Fund
5
S000058927
12/31/2024
Crawford Multi-Asset Income Fund
6
S000038330
12/31/2024
Crawford Small Cap Dividend Fund
7
S000075566
8/31/2024
OneAscent Core Plus Bond ETF
8
S000074252
8/31/2024
OneAscent Large Cap Core ETF
9
S000077262
8/31/2024
OneAscent International Equity ETF
10
S000077261
8/31/2024
OneAscent Emerging Markets ETF
11
S000084956
8/31/2024
OneAscent Small Cap Core ETF
12
S000066743
8/31/2024
Fisher Investments Institutional Group All Foreign Equity Environmental and Social Values Fund
13
S000066753
8/31/2024
Fisher Investments Institutional Group Stock Fund for Retirement Plans
14
S000066751
8/31/2024
Fisher Investments Institutional Group ESG Stock Fund for Retirement Plans
15
S000066752
8/31/2024
Fisher Investments Institutional Group Fixed Income Fund for Retirement Plans
16
S000066750
8/31/2024
Fisher Investments Institutional Group ESG Fixed Income Fund for Retirement Plans
17
S000066744
8/31/2024
Fisher Investments Institutional Group U.S. Large Cap Equity Environmental and Social Values Fund
18
S000066745
8/31/2024
Fisher Investments Institutional Group U.S. Small Cap Equity Fund
19
S000055915
8/31/2024
Tactical Multi-Purpose Fund