Correspondence 0001432353-24-000480 from Global X Funds (CIK 0001432353)
Global X Funds (CIK 0001432353)
Date: Sept. 13, 2024 · CIK: 0001432353 · Accession: 0001432353-24-000480
AI Filing Summary & Sentiment
File numbers found in text: 811-22209
Letter
VIA EDGAR Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-9303 Re: Global X Funds File No. 811-22209
Dear Ms. McDonough:
This letter responds to telephonic comments provided by the Staff of the U.S. Securities and Exchange Commission (the “Staff”) on the Global X Funds’ (the “Registrant”) Form N-CSR for the fiscal year ended November 30, 2022 (accession No. 0001140361-23-038571) related to the Registrant’s series, the Global X Thematic Growth ETF (the “Fund”). We have restated the Staff’s comment as we understand it below, with the Registrant’s response immediately following.
Comment: Please supplementally discuss whether the Registrant performed an analysis of the change in presentation in the financial highlights in accordance with GAAP in order to determine the presentation was appropriate.
Response: The Registrant supplementally confirms that it performed an analysis of the changed presentation and determined the presentation was appropriate.
Please do not hesitate to contact me at (646) 716-3239 if you have any further questions.
Respectfully submitted,
/s/ Jasmin Ali
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Global X Funds
605 Third Avenue, 43rd Floor
New York, NY 10158
September 13, 2024
VIA EDGAR
Ms. Melissa McDonough
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549-9303
Re: Global X Funds
File No. 811-22209
Dear Ms. McDonough:
This letter responds to telephonic comments provided by the Staff of the U.S. Securities and Exchange Commission (the “Staff”) on the Global X Funds’ (the “Registrant”) Form N-CSR for the fiscal year ended November 30, 2022 (accession No. 0001140361-23-038571) related to the Registrant’s series, the Global X Thematic Growth ETF (the “Fund”). We have restated the Staff’s comment as we understand it below, with the Registrant’s response immediately following.
Comment: Please supplementally discuss whether the Registrant performed an analysis of the change in presentation in the financial highlights in accordance with GAAP in order to determine the presentation was appropriate.
Response: The Registrant supplementally confirms that it performed an analysis of the changed presentation and determined the presentation was appropriate.
Please do not hesitate to contact me at (646) 716-3239 if you have any further questions.
Respectfully submitted,
/s/ Jasmin Ali
Jasmin Ali, Esq.
cc: Eric S. Purple, Esq., Stradley Ronon Stevens & Young, LLP