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Correspondence 0001829126-24-004634 from FundVantage Trust (CIK 0001388485)

FundVantage Trust (CIK 0001388485)
Date: July 8, 2024 · CIK: 0001388485 · Accession: 0001829126-24-004634

AI Filing Summary & Sentiment

File numbers found in text: 333-141120, 811-22027

Date
April 30, 2024
Author
FUNDVANTAGE
Form
CORRESP
Company
FundVantage Trust (CIK 0001388485)

Letter

United States Securities and Exchange Commission Division of Investment Management F Street, N.E. Washington, D.C. 20549 Attention: Mr. Jeff Long Re: FundVantage Trust (File Nos. 333-141120; 811-22027)

Dear Mr. Long:

Concurrently herewith, FundVantage Trust (the “Trust”) is filing via EDGAR the Trust’s Form N-CSR for its fiscal year ended April 30, 2024, including a copy of the annual report for each series of the Trust with a fiscal year ended April 30, 2024. With the exception of the combined annual report for the Polen Funds (defined below), each annual report was timely transmitted to each series’ shareholders within 60 days after the close of the fiscal year ended April 30, 2024.1 With respect to the combined annual report for the Polen Funds for the fiscal year ended April 30, 2024, the report was transmitted to shareholders of the Polen Funds on July 8, 2024.

The combined annual report for the Polen Funds was required by Rule 30e-1(d) under the Investment Company Act of 1940, as amended, to be transmitted to shareholders by June 28, 2024. The Fund self-reported that it was experiencing delays in completing its financial statement preparation and audit processes on June 28, 2024 to you, as a member of the staff of the United States Securities and Exchange Commission, via telephonic communication from its legal counsel.

The reason for the delay in transmission was caused by two bank loans issued by a single portfolio company held by Polen Bank Loan Fund and Polen Opportunistic High Yield Fund (the “Affected Funds”) during the fiscal year. These bank loans experienced a restructuring that was effective shortly prior to fiscal year-end. However, the final terms of the restructuring, including final position confirmation statements prepared by the loan agent, were not received by the Affected Funds until after the fiscal year-end. Management required additional time to ensure the restructured loans were properly recorded and disclosed within the financial statements as of fiscal year-end for each Affected Fund. The other Polen Funds did not hold the bank loans at issue; however, the transmission of the combined annual report to shareholders of all Polen Funds was delayed because the Affected Funds were included in the combined annual report.

The Trust’s N-CSR filing is being filed not later than 10 days after June 28, 2024; accordingly, no notification of late filing is required by Rule 12b-25 under the Securities Exchange Act of 1934, as amended.

1 The “Polen Funds” consist of the following series of the Trust: Polen Growth Fund, Polen Global Growth Fund, Polen International Growth Fund, Polen U.S. Small Company Growth Fund, Polen Emerging Markets Growth Fund, Polen U.S. SMID Company Growth Fund, Polen Global SMID Company Growth Fund, Polen Bank Loan Fund, Polen U.S. High Yield Fund and Polen Opportunistic High Yield Fund.

If you have any questions regarding the foregoing, please contact John Falco at Troutman Pepper Hamilton Sanders LLP, counsel to the Trust, at 215.981.4659 (or by email at john.falco@troutman.com).

Sincerely,
FUNDVANTAGE
TRUST

Show Raw Text
CORRESP
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filename1.htm

FUNDVANTAGE
TRUST

103 Bellevue Parkway

Wilmington,
DE 19809

July
8, 2024

By
EDGAR

United
States Securities and Exchange Commission

Division of Investment Management

100
F Street, N.E.

Washington,
D.C. 20549

Attention:
Mr. Jeff Long

  Re:
  FundVantage Trust (File Nos. 333-141120;  811-22027)

Dear
Mr. Long:

Concurrently
herewith, FundVantage Trust (the “Trust”) is filing via EDGAR the Trust’s Form N-CSR for its fiscal year ended April
30, 2024, including a copy of the annual report for each series of the Trust with a fiscal year ended April 30, 2024. With the exception
of the combined annual report for the Polen Funds (defined below), each annual report was timely transmitted to each series’ shareholders
within 60 days after the close of the fiscal year ended April 30, 2024.1 With respect to the combined annual report for
the Polen Funds for the fiscal year ended April 30, 2024, the report was transmitted to shareholders of the Polen Funds on July 8, 2024.

The
combined annual report for the Polen Funds was required by Rule 30e-1(d) under the Investment Company Act of 1940, as amended, to be
transmitted to shareholders by June 28, 2024. The Fund self-reported that it was experiencing delays in completing its financial statement
preparation and audit processes on June 28, 2024 to you, as a member of the staff of the United States Securities and Exchange Commission,
via telephonic communication from its legal counsel.

The
reason for the delay in transmission was caused by two bank loans issued by a single portfolio company held by Polen Bank Loan Fund and
Polen Opportunistic High Yield Fund (the “Affected Funds”) during the fiscal year. These bank loans experienced a restructuring
that was effective shortly prior to fiscal year-end. However, the final terms of the restructuring, including final position confirmation
statements prepared by the loan agent, were not received by the Affected Funds until after the fiscal year-end. Management required additional
time to ensure the restructured loans were properly recorded and disclosed within the financial statements as of fiscal year-end for
each Affected Fund. The other Polen Funds did not hold the bank loans at issue; however, the transmission of the combined annual report
to shareholders of all Polen Funds was delayed because the Affected Funds were included in the combined annual report.

The
Trust’s N-CSR filing is being filed not later than 10 days after June 28, 2024; accordingly, no notification of late filing is
required by Rule 12b-25 under the Securities Exchange Act of 1934, as amended.

 1 The
                                            “Polen Funds” consist of the following series of the Trust: Polen Growth Fund,
                                            Polen Global Growth Fund, Polen International Growth Fund, Polen U.S. Small Company Growth
                                            Fund, Polen Emerging Markets Growth Fund, Polen U.S. SMID Company Growth Fund, Polen Global
                                            SMID Company Growth Fund, Polen Bank Loan Fund, Polen U.S. High Yield Fund and Polen Opportunistic
                                            High Yield Fund.

If
you have any questions regarding the foregoing, please contact John Falco at Troutman Pepper Hamilton Sanders LLP, counsel to the Trust,
at 215.981.4659 (or by email at john.falco@troutman.com).

    Sincerely,

    FUNDVANTAGE
TRUST

    By:
    /s/ Joel L. Weiss

    Name: 
    Joel L. Weiss

    Title:
    President and Chief Executive Officer

  cc:
  John P. Falco, Troutman Pepper Hamilton Sanders LLP

  John
M. Ford, Troutman Pepper Hamilton Sanders LLP

  Brian
D. Goldberg, Polen Capital Management, LLC

  Joshua
L. McCarthy, Polen Capital Credit, LLC