Correspondence 0001193125-25-054615 from PIMCO Equity Series (CIK 0001479360)
PIMCO Equity Series (CIK 0001479360)
Date: March 14, 2025 · CIK: 0001479360 · Accession: 0001193125-25-054615
AI Filing Summary & Sentiment
File numbers found in text: 811-22375
Letter
VIA EDGAR Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: PIMCO Equity Series, File No. 811-22375 (the “Registrant” and each series thereof, a “Fund”)
Dear Mr. Ellington:
In a telephone conversation with me and Elise Kletz of Dechert LLP, you communicated the Securities and Exchange Commission (“SEC”) staff’s (the “Staff”) comment on the most recent annual report for the Registrant following a review of the Registrant’s recent filing.1 A summary of the Staff’s comment, along with the Registrant’s response, is set forth below.
Comment 1: For all ETFs, please explain why each fund does not disclose prominently on its website the table showing the number of days the ETF shares traded at a premium or discount during the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter). See Rule 6c-11(c)(iii) under the 1940 Act.
Response: As discussed and confirmed with you during our telephone conversation, the Registrant confirms that, per Rule 6c-11(c)(iii) under the 1940 Act, each ETF discloses on its website the table showing the number of days the ETF shares traded at a premium or discount during the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter).
* * *
We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at (202) 261-3464 if you wish to discuss this correspondence further.
The PIMCO Equity Series’ most recent annual filing on Form N-CSR, for the period ending June 30, 2024, was filed on September 4, 2024.
Kenneth Ellington
March 14, 2025
Page
Sincerely,
/s/ Adam T. Teufel
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CORRESP 1 filename1.htm CORRESP 1900 K Street, NW Washington, DC 20006-1110 +1 202 261 3300 Main +1 202 261 3333 Fax www.dechert.com March 14, 2025 VIA EDGAR Kenneth Ellington Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: PIMCO Equity Series, File No. 811-22375 (the “Registrant” and each series thereof, a “Fund”) Dear Mr. Ellington: In a telephone conversation with me and Elise Kletz of Dechert LLP, you communicated the Securities and Exchange Commission (“SEC”) staff’s (the “Staff”) comment on the most recent annual report for the Registrant following a review of the Registrant’s recent filing.1 A summary of the Staff’s comment, along with the Registrant’s response, is set forth below. Comment 1: For all ETFs, please explain why each fund does not disclose prominently on its website the table showing the number of days the ETF shares traded at a premium or discount during the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter). See Rule 6c-11(c)(iii) under the 1940 Act. Response: As discussed and confirmed with you during our telephone conversation, the Registrant confirms that, per Rule 6c-11(c)(iii) under the 1940 Act, each ETF discloses on its website the table showing the number of days the ETF shares traded at a premium or discount during the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter). * * * We believe that the foregoing has been responsive to the Staff’s comments. Please call the undersigned at (202) 261-3464 if you wish to discuss this correspondence further. 1 The PIMCO Equity Series’ most recent annual filing on Form N-CSR, for the period ending June 30, 2024, was filed on September 4, 2024. Kenneth Ellington March 14, 2025 Page 2 Sincerely, /s/ Adam T. Teufel Adam T. Teufel cc: Ryan Leshaw, Pacific Investment Management Company LLC Timothy Bekkers, Pacific Investment Management Company LLC Sonia Bui, Pacific Investment Management Company LLC Jaime Dinan, Pacific Investment Management Company LLC