Correspondence 0001464413-24-000020 from Starboard Investment Trust (CIK 0001464413)
Starboard Investment Trust (CIK 0001464413)
Date: April 23, 2024 · CIK: 0001464413 · Accession: 0001464413-24-000020
AI Filing Summary & Sentiment
File numbers found in text: 333-159484, 811-22298
Letter
VIA EDGAR Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Starboard Investment Trust (the “Trust”); File Nos. 333-159484 and 811-22298
Dear Mr. Kernan:
On April 11, 2024, you provided comments by telephone to Tanya Boyle to the annual report for the period ended September 30, 2023 of the Sector Rotation Fund, a series of the Trust (the “Fund”). 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. Follow up comment from 2021 – The Fund’s response in correspondence to staff’s 2021 SOX comments confirmed that the Fund was incorrectly identified as non-diversified in the annual report. The disclosure still refers to the Fund as non-diversified; please correct the disclosure.
Response. The Fund will correct the error going forward.
Comment 2. In the Statement of Operations, in the disclosure regarding realized gains associated with other investment companies, please disclose the distributions of realized gains by other investment companies, if any, separately when disclosing realized gains of investments (see Reg S-X 607-70).
Response. Going forward, the Fund will disclose the distributions of realized gains by other investment companies, if any, separately when disclosing realized gains of investments in the Statement of Operations.
Comment 3. In the Schedule of Investments, in the disclosure regarding money market sweep options, please prospectively disclose the class of shares held of money market funds of part of the title of the issue (see Reg S-X 12-12).
Response. Going forward, the Fund will disclose the class of shares held of money market funds of part of the title of the issue in the Schedule of Investments.
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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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
April 23, 2024
VIA EDGAR
John Kernan
Staff Accountant
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549
Re:
Starboard Investment Trust (the “Trust”); File Nos. 333-159484 and 811-22298
Dear Mr. Kernan:
On April 11, 2024, you provided comments by telephone to Tanya Boyle to the annual report for the period ended September 30, 2023 of the Sector
Rotation Fund, a series of the Trust (the “Fund”). 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. Follow up comment from 2021 – The Fund’s response in correspondence to staff’s 2021 SOX comments confirmed that the Fund was incorrectly identified as
non-diversified in the annual report. The disclosure still refers to the Fund as non-diversified; please correct the disclosure.
Response. The Fund will correct the error going forward.
Comment 2. In the Statement of Operations, in the disclosure regarding realized gains associated with other investment companies, please disclose the distributions of
realized gains by other investment companies, if any, separately when disclosing realized gains of investments (see Reg S-X 607-70).
Response. Going forward, the Fund will disclose the distributions of realized gains by other investment companies, if any, separately when disclosing realized gains of
investments in the Statement of Operations.
Comment 3. In the Schedule of Investments, in the disclosure regarding money market sweep options, please prospectively disclose the class of shares held of money market
funds of part of the title of the issue (see Reg S-X 12-12).
Response. Going forward, the Fund will disclose the class of shares held of money market funds of part of the title of the issue in the Schedule of Investments.
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