SEC Company Response from MUTUAL FUND SERIES TRUST (CIK 0001355064) — Oct 15, 2025
MUTUAL FUND SERIES TRUST (CIK 0001355064)
Date: Oct. 15, 2025 · CIK: 0001355064 · Accession: 0001580642-25-006577
AI Filing Summary & Sentiment
File numbers found in text: 333-132541, 811-21872
Letter
Division of Investment Management U.S. Securities and Exchange Commission 100 F. Street, N.E. Washington, DC 20549 Re: Mutual Fund Series Trust, File Nos. 811-21872, 333-132541
Dear Mr. Manion:
This letter responds to your additional comments with respect to the series in Mutual Fund Series Trust (the “Registrant” or the “Trust”) with a June 30 or September 30 fiscal year end (each a “Fund” and collectively, the “Funds”). The Registrant has authorized Thompson Hine LLP to submit these responses on its behalf.
Comment 6-1: For those Funds that use Mount Vernon Liquid Assets Portfolio as collateral for securities loaned, the disclosure requirements of ASC 820-10-50-6(a) were not met. Please discuss in correspondence why these requirements have not been incorporated in the most recent financial statements.
Response: The Registrant believes the requirements of ASC 820-10-50-6(a) have been satisfied and notes that the securities are exempt from ASC 820-10-50-6(a) because they are valued using NAV as a practical expedient.
Comment 8-1: As of June 30, 2024, Catalyst Enhanced Income Strategy Fund holds a number of investments that cite the US 30-day average SOFR as its base rate which was approximately 5.33%. However, the rate cited on certain GNMA, FNMA and FHLMC securities for the same period is significantly lower at 0.01%. Please address the following in correspondence:
Interest-only securities and principal-only securities typically do not have a reference rate. To the extent the Fund holds interest-only securities and principal-only securities, should they have a reference rate? If not, please ensure proper disclosure is included in future financial statements.
Response: At the outset, the Registrant clarifies its previous response to Comment 8 and has confirmed that the Catalyst Enhanced Income Strategy Fund does not hold any principal-only securities. The Fund does hold inverse interest-only securities. These securities have a reference rate as cited in the Fund’s financial statements.
If you have any questions or additional comments, please call me at (614) 469-3217.
Mr. David Manion
October 15, 2025
Page 2
Very truly yours,
/s/ Philip B. Sineneng
Show Raw Text
CORRESP 1 filename1.htm October 15, 2025 Mr. David Manion Staff Accountant Division of Investment Management Disclosure Review and Accounting Office U.S. Securities and Exchange Commission 100 F. Street, N.E. Washington, DC 20549 Re: Mutual Fund Series Trust, File Nos. 811-21872, 333-132541 Dear Mr. Manion: This letter responds to your additional comments with respect to the series in Mutual Fund Series Trust (the “Registrant” or the “Trust”) with a June 30 or September 30 fiscal year end (each a “Fund” and collectively, the “Funds”). The Registrant has authorized Thompson Hine LLP to submit these responses on its behalf. Comment 6-1: For those Funds that use Mount Vernon Liquid Assets Portfolio as collateral for securities loaned, the disclosure requirements of ASC 820-10-50-6(a) were not met. Please discuss in correspondence why these requirements have not been incorporated in the most recent financial statements. Response: The Registrant believes the requirements of ASC 820-10-50-6(a) have been satisfied and notes that the securities are exempt from ASC 820-10-50-6(a) because they are valued using NAV as a practical expedient. Comment 8-1: As of June 30, 2024, Catalyst Enhanced Income Strategy Fund holds a number of investments that cite the US 30-day average SOFR as its base rate which was approximately 5.33%. However, the rate cited on certain GNMA, FNMA and FHLMC securities for the same period is significantly lower at 0.01%. Please address the following in correspondence: Interest-only securities and principal-only securities typically do not have a reference rate. To the extent the Fund holds interest-only securities and principal-only securities, should they have a reference rate? If not, please ensure proper disclosure is included in future financial statements. Response: At the outset, the Registrant clarifies its previous response to Comment 8 and has confirmed that the Catalyst Enhanced Income Strategy Fund does not hold any principal-only securities. The Fund does hold inverse interest-only securities. These securities have a reference rate as cited in the Fund’s financial statements. If you have any questions or additional comments, please call me at (614) 469-3217. Mr. David Manion October 15, 2025 Page 2 Very truly yours, /s/ Philip B. Sineneng Philip B. Sineneng