Correspondence 0001162044-24-000374 from ARCHER INVESTMENT SERIES TRUST (CIK 0001477491)
ARCHER INVESTMENT SERIES TRUST (CIK 0001477491)
Date: April 16, 2024 · CIK: 0001477491 · Accession: 0001162044-24-000374
AI Filing Summary & Sentiment
File numbers found in text: 333-163981, 811-22356
Letter
VIA EDGAR 100 F Street N.E.Washington DC 20549 Re: Archer Investment Series Trust (“Registrant”) File Nos. 333-163981 / 811-22356
Dear Mrs. DiAngelo Fettig:
Kindly accept this letter in response to our telephone conversation on February 14, 2024, wherein you provided comments to the above referenced registrant’s 2023 Annual Report, Form N-CSR filed on November 9, 2023 and the Registrant’s website.
As to the Registrant’s 2023 Annual Report to Shareholders.
1)
You have noted that on page #5, in the first sentence of the 3rd full para. of the Advisor’s commentary, it states that the Multi-Cap Fund invests in up to 75 equity positions while the Prospectus states in up to 100 equity positions, and you have asked that the Registrant reconcile these two representations.
Response: The Registrant confirms that the Multi-Cap Fund invests in up to 100 equity positions. Accordingly, the Registrant will revise its commentary to more precisely reflect this investment strategy in future filings.
2)
You have asked that Registrant provide additional information relating to the Structures Notes which it invests in, and their financial characteristics reflected in the Registrant’s “Schedule of Investments” in order to provide greater transparency of these investments.
Response: The Registrant believes that the representations made are consistent with industry transparency requirements.
3)
You have asked that the footnote referencing “Variable Rate” appearing on page #23 of the Annual Report, be provide a description of the referenced rate and spread and: (1) the end of
Ms. Christina DiAngelo Fettig
April 16, 2024
Page 2 of 2
period interest rate or (2) disclose the end of period reference rate, as required in Reg. SX 1212 - Footnote #4.
Response: The Registrant in its future filings, to the extent that the current disclosure does not, will modify the referenced “Variable Rate” footnote to provide a description which better satisfies Reg. SX 1212 - Footnote #4.
4)
You asked that the applicable disclosure with respect to N-CSR, Item 11(b) be revised to comply with the instructions as required.
Response: The Registrant, in its future filings, will revise the referenced Item 11(b) disclosure to meet the applicable instructions.
5)
You asked that with respect to the Focus Fund and the Multicap Fund, that the Registrant confirm that these funds are “Diversified” and reflect this in future filings.
Response: The Registrant confirms that the Focus Fund and the Multicap Fund are “Diversified” Funds. Accordingly, the Registrant will reflect this in its future filings.
As to the Registrant’s website:
6)
You have asked that the Registrant update its website to reflect the 2023 Prospectus.
Response: The Registrant confirms that it has updated its website to reflect the 2023 Prospectus.
7)
You noted that the Balanced Fund’s fact sheet, as presented on the website, appears to represent that the Fund holds a percentage range of equity positions which are inconsistent with the Fund’s Principal Investment Strategies as reflected in the fund’s Prospectus.
Response: The Registrant will revise the Balanced Fund’s fact sheet on its website to better reflect the Fund’s Principal Investment Strategy as presented in its Prospectus.
8)
You note that the asset allocation chart appearing on the website seemed to be to be cut off.
Response: The Registrant has revised the applicable chart to resolve this issue
9)
You noted that the Registrant’s Annual and Semi-Annual Reports do not appear to be available on the Registrant’s website.
Response: The Registrant’s website displays its’ Annual and Semi-Annual Reports at the bottom of the “home” of its’ website. .
Ms. Christina DiAngelo Fettig
April 16, 2024
Page 3 of 3
Thank you for your kind attention to the matter. Should you have any questions, please contact me.
Sincerely,
/s/ C. Richard Ropka, Esq.
Show Raw Text
CORRESP 1 filename1.htm Converted by EDGARwiz ROPKA LAW, LLC 215 Fries Mill Road Turnersville, New Jersey 08012 (856) 374-1744 (1-866) 272-8505 (Fax) April 16, 2024 VIA EDGAR Christina DiAngelo Fettig, Senior Staff Accountant U.S. Securities and Exchange CommissionDivision of Investment Management, Disclosure Review Office 100 F Street N.E.Washington DC 20549 Re: Archer Investment Series Trust (“Registrant”) File Nos. 333-163981 / 811-22356 Dear Mrs. DiAngelo Fettig: Kindly accept this letter in response to our telephone conversation on February 14, 2024, wherein you provided comments to the above referenced registrant’s 2023 Annual Report, Form N-CSR filed on November 9, 2023 and the Registrant’s website. As to the Registrant’s 2023 Annual Report to Shareholders. 1) You have noted that on page #5, in the first sentence of the 3rd full para. of the Advisor’s commentary, it states that the Multi-Cap Fund invests in up to 75 equity positions while the Prospectus states in up to 100 equity positions, and you have asked that the Registrant reconcile these two representations. Response: The Registrant confirms that the Multi-Cap Fund invests in up to 100 equity positions. Accordingly, the Registrant will revise its commentary to more precisely reflect this investment strategy in future filings. 2) You have asked that Registrant provide additional information relating to the Structures Notes which it invests in, and their financial characteristics reflected in the Registrant’s “Schedule of Investments” in order to provide greater transparency of these investments. Response: The Registrant believes that the representations made are consistent with industry transparency requirements. 3) You have asked that the footnote referencing “Variable Rate” appearing on page #23 of the Annual Report, be provide a description of the referenced rate and spread and: (1) the end of Ms. Christina DiAngelo Fettig April 16, 2024 Page 2 of 2 period interest rate or (2) disclose the end of period reference rate, as required in Reg. SX 1212 - Footnote #4. Response: The Registrant in its future filings, to the extent that the current disclosure does not, will modify the referenced “Variable Rate” footnote to provide a description which better satisfies Reg. SX 1212 - Footnote #4. 4) You asked that the applicable disclosure with respect to N-CSR, Item 11(b) be revised to comply with the instructions as required. Response: The Registrant, in its future filings, will revise the referenced Item 11(b) disclosure to meet the applicable instructions. 5) You asked that with respect to the Focus Fund and the Multicap Fund, that the Registrant confirm that these funds are “Diversified” and reflect this in future filings. Response: The Registrant confirms that the Focus Fund and the Multicap Fund are “Diversified” Funds. Accordingly, the Registrant will reflect this in its future filings. As to the Registrant’s website: 6) You have asked that the Registrant update its website to reflect the 2023 Prospectus. Response: The Registrant confirms that it has updated its website to reflect the 2023 Prospectus. 7) You noted that the Balanced Fund’s fact sheet, as presented on the website, appears to represent that the Fund holds a percentage range of equity positions which are inconsistent with the Fund’s Principal Investment Strategies as reflected in the fund’s Prospectus. Response: The Registrant will revise the Balanced Fund’s fact sheet on its website to better reflect the Fund’s Principal Investment Strategy as presented in its Prospectus. 8) You note that the asset allocation chart appearing on the website seemed to be to be cut off. Response: The Registrant has revised the applicable chart to resolve this issue 9) You noted that the Registrant’s Annual and Semi-Annual Reports do not appear to be available on the Registrant’s website. Response: The Registrant’s website displays its’ Annual and Semi-Annual Reports at the bottom of the “home” of its’ website. . Ms. Christina DiAngelo Fettig April 16, 2024 Page 3 of 3 Thank you for your kind attention to the matter. Should you have any questions, please contact me. Sincerely, /s/ C. Richard Ropka, Esq. C. Richard Ropka, Esq. CRR cc: client