Correspondence 0001580642-25-001394 from Pinnacle Capital Management Funds Trust (CIK 0001497362)
Pinnacle Capital Management Funds Trust (CIK 0001497362)
Date: March 5, 2025 · CIK: 0001497362 · Accession: 0001580642-25-001394
AI Filing Summary & Sentiment
File numbers found in text: 811-22445
Letter
VIA EDGAR Division of Investment Management 100 F Street, NE Washington, D.C. 20549 Re: Pinnacle Capital Management Funds Trust (the “Registrant”) File No. 811-22445
Dear Mr. Kernan:
On behalf of the Registrant, and with respect to the series of the Registrant, the following is the Registrant’s response to the comment of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) provided on February 10, 2025, with regard to the Registrant’s Form N-CSR for the reporting period ended October 31, 2024 (the “Report”). The Staff comment is summarized below, followed by the Registrant’s response to the comment.
1. Staff Comment: It appears that the website address referenced in the tailored shareholder report does not contain all of the Items 7 through 11 of Form N-CSR as required by Rule 30b1-(B)(2)(ii). Please describe how the Registrant will comply with such website reporting requirements prospectively and new controls implemented to ensure compliance with the rule.
Registrant’s Response: The Registrant confirms that it posted the information required by Items 7 through 11 of Form N-CSR on its website under the heading: “Annual Financial Statements.” Consistent with the guidance provided by the Staff in ADI 2024-14: Tailored Shareholder Report Common Issues, the Registrant has revised the heading on its website to be more descriptive of the information required by Items 7 through 11 of Form N-CSR. The heading on the Registrant’s website is now: “Annual Financial Statements and Additional Information.”
Sincerely,
/s/ Jesse D. Hallee
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Pinnacle Capital Management Funds Trust
5845 Widewaters
Parkway, Suite 300
East Syracuse, New York 13057
March 5, 2025
VIA EDGAR
John Kernan
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, D.C. 20549
Re:
Pinnacle Capital Management Funds Trust (the
“Registrant”)
File No. 811-22445
Dear Mr. Kernan:
On behalf of the Registrant, and with respect
to the series of the Registrant, the following is the Registrant’s response to the comment of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) provided on February 10, 2025, with regard to the
Registrant’s Form N-CSR for the reporting period ended October 31, 2024 (the “Report”). The Staff comment is
summarized below, followed by the Registrant’s response to the comment.
1. Staff Comment: It appears that the website address referenced in the tailored shareholder
report does not contain all of the Items 7 through 11 of Form N-CSR as required by Rule 30b1-(B)(2)(ii). Please describe how the Registrant
will comply with such website reporting requirements prospectively and new controls implemented to ensure compliance with the rule.
Registrant’s Response: The Registrant confirms that it posted
the information required by Items 7 through 11 of Form N-CSR on its website under the heading: “Annual
Financial Statements.” Consistent with the guidance provided by the Staff in ADI 2024-14: Tailored
Shareholder Report Common Issues, the Registrant has revised the heading on its website to be more
descriptive of the information required by Items 7 through 11 of Form N-CSR. The heading on the Registrant’s
website is now: “Annual Financial Statements and Additional Information.”
Sincerely,
/s/ Jesse D. Hallee
Jesse D. Hallee
Secretary
cc: Matthew N. Wells, Esq., Bond, Schoeneck &
King PLLC