Correspondence 0001387131-23-011454 from abrdn Palladium ETF Trust (PALL) (CIK 0001459862) (PALL)
abrdn Palladium ETF Trust (PALL) (CIK 0001459862)
Date: Sept. 21, 2023 · CIK: 0001459862 · Accession: 0001387131-23-011454
AI Filing Summary & Sentiment
File numbers found in text: 333-272037
Letter
VIA EDGAR CORRESPONDENCE Division of Corporation Finance Office of Crypto Assets F Street, NE Washington, D.C. 20549-4644 Re: abrdn Palladium ETF Trust Amendment No. 1 to Registration Statement on Form S-3 filed on August 24, 2023 (SEC File No. 333-272037) (the “Registration Statement”)
Dear Ms. Livingston and Mr. Brown:
We are writing in response to the comment you provided in writing on behalf of the Securities and Exchange Commission (the “SEC”) staff (the “Staff”) to Steven Dunn on September 11, 2023, with respect to the Registration Statement for the abrdn Physical Palladium Shares ETF (the “Registrant”). On behalf of the “Registrant, we have reproduced your comment below and provided the Registrant’s response immediately thereafter. To the extent not otherwise defined herein, capitalized terms have the meanings attributed to such terms in the Registration Statement.
Historical Chart of the Price of Palladium, page 16
Comment: 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.
Response: The Registration Statement has been revised to address the Staff’s comment.
Should you have any questions, please feel free to contact me at (617) 728-7127.
Sincerely,
/s/
Stephanie A. Capistron
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CORRESP
1
filename1.htm
One International Place, 40th Floor
100 Oliver Street
Boston, MA 02110-2605
+1 617 728 7100 Main
+1 617 275 8364 Fax
www.dechert.com
STEPHANIE CAPISTRON
Stephanie.Capistron@dechert.com
+1 617 728 7127 Direct
+1 617 275 8364 Fax
September
21, 2023
VIA
EDGAR CORRESPONDENCE
Jessica
Livingston
John
Dana Brown
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
Office
of Crypto Assets
100
F Street, NE
Washington,
D.C. 20549-4644
Re: abrdn
Palladium ETF Trust Amendment No. 1 to Registration Statement on Form S-3 filed on August
24, 2023 (SEC File No. 333-272037) (the “Registration Statement”)
Dear
Ms. Livingston and Mr. Brown:
We
are writing in response to the comment you provided in writing on behalf of the Securities and Exchange Commission (the “SEC”)
staff (the “Staff”) to Steven Dunn on September 11, 2023, with respect to the Registration Statement for the abrdn Physical
Palladium Shares ETF (the “Registrant”). On behalf of the “Registrant, we have reproduced your comment below and provided
the Registrant’s response immediately thereafter. To the extent not otherwise defined herein, capitalized terms have the meanings
attributed to such terms in the Registration Statement.
Historical
Chart of the Price of Palladium, page 16
Comment: 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.
Response: The
Registration Statement has been revised to address the Staff’s comment.
Should
you have any questions, please feel free to contact me at (617) 728-7127.
Sincerely,
/s/
Stephanie A. Capistron
Stephanie
A. Capistron
cc: Thomas
C. Bogle
Lucia Sitar, abrdn Inc.
Brian Kordeck, abrdn Inc.