SEC Comment Letter for abrdn Palladium ETF Trust (PALL) (CIK 0001459862) (PALL) — May 15, 2020
abrdn Palladium ETF Trust (PALL) (CIK 0001459862)
Date: May 15, 2020 · CIK: 0001459862 · Accession: 0000000000-20-004357
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File numbers found in text: 333-238125
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United States securities and exchange commission logo
May 15, 2020
Christopher Demetriou
President and Chief Executive Officer
Aberdeen Standard Investments ETFs Sponsor LLC
712 Fifth Avenue, 49th Floor
New York, NY 10019
Re:Aberdeen Standard Palladium ETF Trust
Registration Statement on Form S-3
Filed May 8, 2020
File No. 333-238125
Dear Mr. Demetriou:
This is to advise you that we have not reviewed and will not review your registration
statement.
Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please contact David Lin, Staff Attorney, at (202) 551-3552 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance