Correspondence 0001829126-24-007031 from AdvisorShares Trust (CIK 0001408970)
AdvisorShares Trust (CIK 0001408970)
Date: Oct. 28, 2024 · CIK: 0001408970 · Accession: 0001829126-24-007031
AI Filing Summary & Sentiment
File numbers found in text: 333-157876, 811-22110
Letter
VIA EDGAR Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: AdvisorShares Trust (File Nos. 333-157876 and 811-22110)
Dear Mr. Bellacicco:
On behalf of AdvisorShares Trust (the “Trust”), this letter responds to a comment relating to the Trust’s Post-Effective Amendment No. 226, which was filed on August 28, 2024. For ease of reference, set forth below is the comment followed by the Trust’s response.
Comment. Please supplementally explain the reason for changing the name of the AdvisorShares MSOS 2x Daily ETF (the “Fund”) to AdvisorShares MSOS Daily Leveraged ETF.
Response. The Trust represents that the Fund’s name is being changed to take into account the effect of various factors on the Fund’s ability to achieve exactly two times the daily total return of the AdvisorShares Pure US Cannabis ETF (for example, fees and expenses, assets under management, volatility in the cannabis market, end-of-day market volatility, end-of-day capacity constraints, counterparty limitations, and regulatory limitations). While the Fund continues to seek to achieve two times the daily total return, its actual daily investment results have been slightly above or slightly below two times the daily total return; therefore, the Fund is changing its name and adding “approximately” to its objective and strategy disclosure.
If you have questions or comments, please do not hesitate to contact me at 202.373.6091.
Sincerely,
/s/ Magda El Guindi-Rosenbaum
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filename1.htm
Magda
El Guindi-Rosenbaum
+1.202.373.6091
mer@morganlewis.com
VIA EDGAR
October 28, 2024
Christopher R. Bellacicco, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re:
AdvisorShares Trust (File Nos. 333-157876 and 811-22110)
Dear Mr. Bellacicco:
On behalf of AdvisorShares Trust
(the “Trust”), this letter responds to a comment relating to the Trust’s Post-Effective Amendment No. 226, which was
filed on August 28, 2024. For ease of reference, set forth below is the comment followed by the Trust’s response.
Comment. Please
supplementally explain the reason for changing the name of the AdvisorShares MSOS 2x Daily ETF (the “Fund”) to AdvisorShares
MSOS Daily Leveraged ETF.
Response. The
Trust represents that the Fund’s name is being changed to take into account the effect of various factors on the Fund’s ability
to achieve exactly two times the daily total return of the AdvisorShares Pure US Cannabis ETF (for example, fees and expenses, assets
under management, volatility in the cannabis market, end-of-day market volatility, end-of-day capacity constraints, counterparty limitations,
and regulatory limitations). While the Fund continues to seek to achieve two times the daily total return, its actual daily investment
results have been slightly above or slightly below two times the daily total return; therefore, the Fund is changing its name and adding
“approximately” to its objective and strategy disclosure.
If you have questions or comments,
please do not hesitate to contact me at 202.373.6091.
Sincerely,
/s/ Magda El Guindi-Rosenbaum
Magda El Guindi-Rosenbaum
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004
+1.202.739.3000
United States
+1.202.739.3001