SEC Comment Letter 0000000000-24-007754 to Invesco CurrencyShares British Pound Sterling Trust (FXB) (CIK 0001353611) (FXB)
Invesco CurrencyShares British Pound Sterling Trust (FXB) (CIK 0001353611)
Date: July 9, 2024 · CIK: 0001353611 · Accession: 0000000000-24-007754
AI Filing Summary & Sentiment
File numbers found in text: 333-280626
Letter
July 9, 2024 Brian Hartigan Chief Executive Officer Invesco CurrencyShares British Pound Sterling Trust 3500 Lacey Road, Suite 700 Downers Grove, Illinois 60515 Re:Invesco CurrencyShares British Pound Sterling Trust Registration Statement on Form S-3 Filed July 1, 2024 File No. 333-280626 Dear Brian Hartigan: We have conducted a limited review of your registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Registration Statement on Form S-3 General 1.It appears that the aggregate market value of your common equity held by non-affiliates during the 60 days prior to July 1, 2024 did not exceed the $75 million threshold that General Instruction I.B.1 of Form S-3 specifies. Please provide us with your analysis demonstrating your ability to use Form S-3 pursuant to General Instruction I.B.1, or if you are relying on General Instruction I.B.6 for Form S- 3 eligibility, include the information required pursuant to Instruction 7 to General Instruction I.B.6. Alternatively, please amend your registration statement on an appropriate form. 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.
July 9, 2024 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Lulu Cheng at 202-551-3811 or Sandra Hunter Berkheimer at 202-551- 3758 with any other questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc:Patrick Daugherty
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July 9, 2024
Brian Hartigan
Chief Executive Officer
Invesco CurrencyShares British Pound Sterling Trust
3500 Lacey Road, Suite 700
Downers Grove, Illinois 60515
Re:Invesco CurrencyShares British Pound Sterling Trust
Registration Statement on Form S-3
Filed July 1, 2024
File No. 333-280626
Dear Brian Hartigan:
We have conducted a limited review of your registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Registration Statement on Form S-3
General
1.It appears that the aggregate market value of your common equity held by non-affiliates
during the 60 days prior to July 1, 2024 did not exceed the $75 million threshold that
General Instruction I.B.1 of Form S-3 specifies. Please provide us with your analysis
demonstrating your ability to use Form S-3 pursuant to General Instruction I.B.1, or if you
are relying on General Instruction I.B.6 for Form S- 3 eligibility, include the information
required pursuant to Instruction 7 to General Instruction I.B.6. Alternatively, please
amend your registration statement on an appropriate form.
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.
July 9, 2024
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Lulu Cheng at 202-551-3811 or Sandra Hunter Berkheimer at 202-551-
3758 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Patrick Daugherty