Correspondence 0001580642-25-003273 from VALUED ADVISERS TRUST (CIK 0001437249)
VALUED ADVISERS TRUST (CIK 0001437249)
Date: May 23, 2025 · CIK: 0001437249 · Accession: 0001580642-25-003273
AI Filing Summary & Sentiment
File numbers found in text: 333-151672, 811-22208
Letter
VIA EDGAR ========== Mindy Rotter Securities and Exchange Commission Filing Desk 100 F Street, N.E. Washington, DC 20549 RE: Valued Advisers Trust, File Nos. 333-151672; 811-22208
Dear Ms. Rotter,
On May 6, 2025, you provided comments by telephone to Tanya Boyle to the annual report and Form N-CSR for the period ended January 31, 2025 of the Channing Intrinsic Value Small-Cap Fund and Regan Floating Rate MBS ETF, each a series of the Trust (the “Funds”). Please find below a summary of those comments and the Trust's responses, which the Trust has authorized DLA Piper LLP to make on behalf of the Trust.
Comment 1. The line graph presented for Channing Intrinsic Value Small-Cap Fund does not assume a $100,000 initial investment as disclosed in the prospectus. Please explain in correspondence why the line graph does not conform to Item 27A(d)(2), Instruction 1 of Form N-1A.
Response. The calculation of the line graph presented for Channing Intrinsic Value Small-Cap Fund should have assumed a $100k investment rather than a $10k investment as disclosed in the prospectus. The Registrant will correct the error going forward.
Comment 2. The staff notes that the response to Item 11 in Form N-CSR that the information is included under Item 7 is not applicable with respect to the Channing Intrinsic Value Small-Cap Fund and Regan Floating Rate MBS ETF. Please explain in correspondence why this item was not included for these funds and cite the instructions in your response.
Response. The board of the Registrant did not approve the renewal of any investment advisory contract during the most recent fiscal half year of the Channing Intrinsic Value Small-Cap Fund
Page Two
and Regan Floating Rate MBS ETF, so the disclosure regarding the approval was not included in accordance with the instructions to Item 11. The response with respect to these two funds should have been not applicable rather than referring back to the information provided in Item 7.
Comment 3. The expense structure of the Regan Floating Rate MBS ETF appears to be arranged in a unitary fee structure whereby the adviser is obligated to pay service providers on behalf of the fund. Please describe in correspondence if the adviser is current on all payments to all service providers. In addition, confirm that the advisory agreement on file with the commission contains provisions that the adviser will pay the fund’s service providers.
Response. The administrator has confirmed to the Registrant that the adviser is current on all payments to all service providers. The Registrant confirms that the advisory agreement on file with the commission contains provisions that the adviser will pay the fund’s service providers.
* * *
If you have any questions or comments, please contact the undersigned at 404.736.7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
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filename1.htm
DLA Piper LLP (US)
One Atlantic Center
1201 West Peachtree Street
Suite 2900
Atlanta, Georgia 30309-3449
www.dlapiper.com
Tanya L. Boyle
tanya.boyle@us.dlapiper.com
T 404.736.7863
F 404.682.7863
May 23, 2025
VIA EDGAR
==========
Mindy Rotter
Staff Accountant
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549
RE: Valued Advisers Trust, File Nos. 333-151672; 811-22208
Dear Ms. Rotter,
On May 6, 2025, you provided comments by telephone
to Tanya Boyle to the annual report and Form N-CSR for the period ended January 31, 2025 of the Channing Intrinsic Value Small-Cap
Fund and Regan Floating Rate MBS ETF, each a series of the Trust (the “Funds”). Please find below a summary of those comments
and the Trust's responses, which the Trust has authorized DLA Piper LLP to make on behalf of the Trust.
Comment 1. The line graph presented
for Channing Intrinsic Value Small-Cap Fund does not assume a $100,000 initial investment as disclosed in the prospectus. Please explain
in correspondence why the line graph does not conform to Item 27A(d)(2), Instruction 1 of Form N-1A.
Response. The calculation of the line
graph presented for Channing Intrinsic Value Small-Cap Fund should have assumed a $100k investment rather than a $10k investment as disclosed
in the prospectus. The Registrant will correct the error going forward.
Comment 2. The staff notes that the
response to Item 11 in Form N-CSR that the information is included under Item 7 is not applicable with respect to the Channing Intrinsic
Value Small-Cap Fund and Regan Floating Rate MBS ETF. Please explain in correspondence why this item was not included for these funds
and cite the instructions in your response.
Response. The board of the Registrant
did not approve the renewal of any investment advisory contract during the most recent fiscal half year of the Channing Intrinsic Value
Small-Cap Fund
Page Two
and Regan Floating Rate MBS ETF, so the disclosure
regarding the approval was not included in accordance with the instructions to Item 11. The response with respect to these two funds should
have been not applicable rather than referring back to the information provided in Item 7.
Comment 3. The expense structure of
the Regan Floating Rate MBS ETF appears to be arranged in a unitary fee structure whereby the adviser is obligated to pay service providers
on behalf of the fund. Please describe in correspondence if the adviser is current on all payments to all service providers. In addition,
confirm that the advisory agreement on file with the commission contains provisions that the adviser will pay the fund’s service
providers.
Response. The administrator has confirmed
to the Registrant that the adviser is current on all payments to all service providers. The Registrant confirms that the advisory agreement
on file with the commission contains provisions that the adviser will pay the fund’s service providers.
* * *
If you have any questions or comments, please
contact the undersigned at 404.736.7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
Tanya L. Boyle