Correspondence 0001580642-25-001842 from Copeland Trust (CIK 0001502745)
Copeland Trust (CIK 0001502745)
Date: March 21, 2025 · CIK: 0001502745 · Accession: 0001580642-25-001842
AI Filing Summary & Sentiment
Letter
Via edgar correspondence Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Comments on Copeland Trust (the “Registrant”) November 30, 2024 Annual Financial Statements and Additional Information (the “November Financial Statements”)
Dear Mr. Eskildsen:
On behalf of the Registrant, we are filing this letter to respond in writing to the Staff’s comment on the November Financial Statements, which were submitted via EDGAR to the Securities and Exchange Commission on December 10, 2024. The Staff’s comment was conveyed to the Registrant by telephone on February 28, 2025. Below is the Staff’s comment on the November Financial Statements and the Registrant’s response thereto.
Comment: Please explain why the total values for the stocks with a footnote (a) designation do not align with the Level 2 or Level 3 assets listed on pages 30-31 of the November Financial Statements.
Response: The Registrant has reviewed the Schedule of Investments for the Copeland International Small Cap Fund (the “Fund”) and the table in Note 2 to the November Financial Statements that lists the values of the Fund’s Level 2 securities. The Registrant has determined that, in the November Financial Statements, several fair valued securities in the Fund’s Schedule of Investments inadvertently exclude after their names a footnote “(a)” designation to explain that the value of the security had been determined in good faith under policies of the Board of Trustees. As a result, the total value of the fair valued securities footnoted in the Schedule of Investments does not correspond to the total value of fair valued securities included in the table in Note 2 to the November Financial Statements. The Registrant has confirmed that the total value of fair valued securities of $454,534 referenced on page 31 of the November Financial Statements is correct and that all fair valued securities are included in the Fund’s Schedule of Investments, although some are not marked with a footnote (a). The Registrant hereby undertakes to consistently include the applicable footnote in the financial statements for future reporting periods.
1401 New York Avenue NW, Suite 500 | Washington, DC 20005 | T +1 202 312 3320 | F +1 202 312 3322
Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
U.S. Securities and Exchange Commission
March 21, 2025
Page 2
We trust the foregoing is responsive to your comment. If you have any questions, you can reach me at (202) 312-3385.
Very truly yours,
/s/ Kimberly Karcewski Vargo
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Chicago
New York
Washington, DC
London
San Francisco
Los Angeles
Singapore
Dallas
Miami
vedderprice.com
March 21, 2025
Kimberly Karcewski Vargo
Shareholder
+1 (202) 312 3385
kvargo@vedderprice.com
Via edgar correspondence
Attn: Chad D. Eskildsen
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: Comments on Copeland Trust (the “Registrant”) November 30, 2024 Annual Financial Statements and Additional Information
(the “November Financial Statements”)
Dear Mr. Eskildsen:
On behalf of the Registrant, we are filing this letter
to respond in writing to the Staff’s comment on the November Financial Statements, which were submitted via EDGAR to the Securities
and Exchange Commission on December 10, 2024. The Staff’s comment was conveyed to the Registrant by telephone on February 28, 2025.
Below is the Staff’s comment on the November Financial Statements and the Registrant’s response thereto.
Comment: Please
explain why the total values for the stocks with a footnote (a) designation do not align with the Level 2 or Level 3 assets listed on
pages 30-31 of the November Financial Statements.
Response: The Registrant has reviewed
the Schedule of Investments for the Copeland International Small Cap Fund (the “Fund”) and the table in Note 2 to the November
Financial Statements that lists the values of the Fund’s Level 2 securities. The Registrant has determined that, in the November
Financial Statements, several fair valued securities in the Fund’s Schedule of Investments inadvertently exclude after their names
a footnote “(a)” designation to explain that the value of the security had been determined in good faith under policies of
the Board of Trustees. As a result, the total value of the fair valued securities footnoted in the Schedule of Investments does not correspond
to the total value of fair valued securities included in the table in Note 2 to the November Financial Statements. The Registrant has
confirmed that the total value of fair valued securities of $454,534 referenced on page 31 of the November Financial Statements is correct
and that all fair valued securities are included in the Fund’s Schedule of Investments, although some are not marked with a footnote
(a). The Registrant hereby undertakes to consistently include the applicable footnote in the financial statements for future reporting
periods.
1401 New York Avenue NW, Suite 500 | Washington, DC 20005 | T +1 202
312 3320 | F +1 202 312 3322
Vedder Price P.C. is affiliated
with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd.,
which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
U.S. Securities and Exchange Commission
March 21, 2025
Page 2
We trust the foregoing is responsive
to your comment. If you have any questions, you can reach me at (202) 312-3385.
Very truly yours,
/s/ Kimberly Karcewski Vargo
Kimberly Karcewski Vargo
Shareholder
KV/dla