SEC Comment Letter 0000000000-23-003517 to United States Commodity Index Funds Trust (CPER, USCI) (CIK 0001479247) (CPER)
United States Commodity Index Funds Trust (CPER, USCI) (CIK 0001479247)
Date: April 10, 2023 · CIK: 0001479247 · Accession: 0000000000-23-003517
AI Filing Summary & Sentiment
File numbers found in text: 001-34833
Letter
United States securities and exchange commission logo April 10, 2023 John P. Love President and Chief Executive Officer United United States Commodity Funds LLC 1850 Mt. Diablo Boulevard Suite 640 Walnut Creek, CA 94596 Re:United States Commodity Index Funds Trust Form 10-K for the year ended December 31, 2022 Filed February 27, 2023 File No. 001-34833 Dear John P. Love: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
Form 10-K for the year ended December 31, 2022 Item 9A. Controls and Procedures, page 132 1.We note you provide the required separate disclosures by each of the Trust and each active series in your financial statements, audit reports, disclosure controls and procedures, and internal control over financial reporting. In addition, you should also include a statement that the CEO/CFO certifications are applicable to each of the series as well as the Trust. Please represent to us that you will revise future periodic filings to comply. In closing, 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.
FirstName LastNameJohn P. Love Comapany NameUnited United States Commodity Funds LLC April 10, 2023 Page 2 FirstName LastName John P. Love United United States Commodity Funds LLC April 10, 2023 Page 2 You may contact Bonnie Baynes at (202) 551-4924 or Mark Brunhofer at (202) 551- 3638 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets
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United States securities and exchange commission logo
April 10, 2023
John P. Love
President and Chief Executive Officer
United United States Commodity Funds LLC
1850 Mt. Diablo Boulevard
Suite 640
Walnut Creek, CA 94596
Re:United States Commodity Index Funds Trust
Form 10-K for the year ended December 31, 2022
Filed February 27, 2023
File No. 001-34833
Dear John P. Love:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
Form 10-K for the year ended December 31, 2022
Item 9A. Controls and Procedures, page 132
1.We note you provide the required separate disclosures by each of the Trust and each
active series in your financial statements, audit reports, disclosure controls and
procedures, and internal control over financial reporting. In addition, you should also
include a statement that the CEO/CFO certifications are applicable to each of the series as
well as the Trust. Please represent to us that you will revise future periodic filings to
comply.
In closing, 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.
FirstName LastNameJohn P. Love
Comapany NameUnited United States Commodity Funds LLC
April 10, 2023 Page 2
FirstName LastName
John P. Love
United United States Commodity Funds LLC
April 10, 2023
Page 2
You may contact Bonnie Baynes at (202) 551-4924 or Mark Brunhofer at (202) 551-
3638 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets