SEC Comment Letter 0000000000-23-010023 to abrdn Palladium ETF Trust (PALL) (CIK 0001459862) (PALL)
abrdn Palladium ETF Trust (PALL) (CIK 0001459862)
Date: Sept. 11, 2023 · CIK: 0001459862 · Accession: 0000000000-23-010023
AI Filing Summary & Sentiment
File numbers found in text: 333-272037
Letter
United States securities and exchange commission logo September 11, 2023 Steven Dunn President and Chief Executive Officer abrdn Palladium ETF Trust 1900 Market Street, Suite 200 Philadelphia, PA 19103 Re:abrdn Palladium ETF Trust Amendment No.1 to Registration Statement on Form S-3 Filed August 24, 2023 File No. 333-272037 Dear Steven Dunn: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 1, 2023 letter. Amendment to Form S-3 filed August 24, 2023 Historical Chart of the Price of Palladium, page 16 1.Refer to your response and revised disclosure to comment 4. We reissue the comment in part, as we do not see the requested revisions to add additional, more timely disclosure about palladium's prices in 2023 and how they compare to pricing in previous years and to include quantitative and qualitative disclosures that address 2023 price declines and the reasons for the declines.
FirstName LastNameSteven Dunn Comapany Nameabrdn Palladium ETF Trust September 11, 2023 Page 2 FirstName LastName Steven Dunn abrdn Palladium ETF Trust September 11, 2023 Page 2 Please contact Jessica Livingston at 202-551-3448 or John Dana Brown at 202-551- 3859 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc: Stephanie A. Capistron
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United States securities and exchange commission logo
September 11, 2023
Steven Dunn
President and Chief Executive Officer
abrdn Palladium ETF Trust
1900 Market Street, Suite 200
Philadelphia, PA 19103
Re:abrdn Palladium ETF Trust
Amendment No.1 to
Registration Statement on Form S-3
Filed August 24, 2023
File No. 333-272037
Dear Steven Dunn:
We have reviewed your amended registration statement and have the following
comments. In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our June 1, 2023 letter.
Amendment to Form S-3 filed August 24, 2023
Historical Chart of the Price of Palladium, page 16
1.Refer to your response and revised disclosure to comment 4. We reissue the comment
in part, as we do not see the requested revisions to add additional, more timely disclosure
about palladium's prices in 2023 and how they compare to pricing in previous years and to
include quantitative and qualitative disclosures that address 2023 price declines and the
reasons for the declines.
FirstName LastNameSteven Dunn
Comapany Nameabrdn Palladium ETF Trust
September 11, 2023 Page 2
FirstName LastName
Steven Dunn
abrdn Palladium ETF Trust
September 11, 2023
Page 2
Please contact Jessica Livingston at 202-551-3448 or John Dana Brown at 202-551-
3859 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc: Stephanie A. Capistron