Correspondence 0001193125-24-015536 from Advisers Investment Trust (CIK 0001516523)
Advisers Investment Trust (CIK 0001516523)
Date: Jan. 25, 2024 · CIK: 0001516523 · Accession: 0001193125-24-015536
AI Filing Summary & Sentiment
File numbers found in text: 333-173080, 811-22538
Letter
Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 202-551-6751
Re: Advisers Investment Trust, File Nos. 333-173080 and 811-22538 (Vontobel)
Dear Ms. White:
On November 22, 2023, Advisers Investment Trust (the “Trust” or the “Registrant”), on behalf of Vontobel U.S. Equity Institutional Fund (the “Fund”), filed post-effective amendment number 109 to the Trust’s registration statement (the “Amendment”). The Amendment was filed pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended, to register shares of the Funds. On January 5, 2024, you provided comments to the Amendment by phone to Matthew Tobin. The Registrant filed a response to your comments on January 19, 2023, and you provided a follow up to the response to Comment 7 on January 23, 2024.
Set forth below is your comment followed by the response, which the Registrant has authorized Thompson Hine LLP to make on its behalf.
1. Comment: In response to our comment that the Fund is disclose the name of the party that conducted an independent verification of the composite performance returns table on page 16 of the prospectus, you state that because the verification reports are available to investors upon request, the Registrant does not believe it is necessary or useful to disclose in the Fund prospectus the name of the firm providing the verification. We disagree with your response and request that the Registrant disclose the name of the party that conducted the verification. Also, please include a consent for the verification per Rule 436 under the 33 Act.
Response: The disclosure in the footnote following the composite performance returns table has been revised to disclose the name of the party providing the verification. A consent for the verification has been filed as an exhibit to the post-effective amendment.
Michael.Wible@ThompsonHine.com Fax: 614.469.3361 Phone: 614.469.3297
THOMPSON HINE LLP
ATTORNEYS AT LAW
41 South High Street
Suite 1700
Columbus, Ohio 43215-6101
www.ThompsonHine.com
Phone: 614.469.3200
Fax: 614.469.3361
Allison White
U.S. Securities and Exchange Commission
Division of Investment Management
January 25, 2024
Page 2
If you have any questions about the responses set forth above, please contact the undersigned at 614.469.3297 or Michael.Wible@thompsonhine.com.
Best regards,
/s/ Michael Wible
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CORRESP 1 filename1.htm CORRESP January 25, 2024 Allison White U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 202-551-6751 Re: Advisers Investment Trust, File Nos. 333-173080 and 811-22538 (Vontobel) Dear Ms. White: On November 22, 2023, Advisers Investment Trust (the “Trust” or the “Registrant”), on behalf of Vontobel U.S. Equity Institutional Fund (the “Fund”), filed post-effective amendment number 109 to the Trust’s registration statement (the “Amendment”). The Amendment was filed pursuant to Rule 485(a)(1) under the Securities Act of 1933, as amended, to register shares of the Funds. On January 5, 2024, you provided comments to the Amendment by phone to Matthew Tobin. The Registrant filed a response to your comments on January 19, 2023, and you provided a follow up to the response to Comment 7 on January 23, 2024. Set forth below is your comment followed by the response, which the Registrant has authorized Thompson Hine LLP to make on its behalf. 1. Comment: In response to our comment that the Fund is disclose the name of the party that conducted an independent verification of the composite performance returns table on page 16 of the prospectus, you state that because the verification reports are available to investors upon request, the Registrant does not believe it is necessary or useful to disclose in the Fund prospectus the name of the firm providing the verification. We disagree with your response and request that the Registrant disclose the name of the party that conducted the verification. Also, please include a consent for the verification per Rule 436 under the 33 Act. Response: The disclosure in the footnote following the composite performance returns table has been revised to disclose the name of the party providing the verification. A consent for the verification has been filed as an exhibit to the post-effective amendment. Michael.Wible@ThompsonHine.com Fax: 614.469.3361 Phone: 614.469.3297 THOMPSON HINE LLP ATTORNEYS AT LAW 41 South High Street Suite 1700 Columbus, Ohio 43215-6101 www.ThompsonHine.com Phone: 614.469.3200 Fax: 614.469.3361 Allison White U.S. Securities and Exchange Commission Division of Investment Management January 25, 2024 Page 2 If you have any questions about the responses set forth above, please contact the undersigned at 614.469.3297 or Michael.Wible@thompsonhine.com. Best regards, /s/ Michael Wible Michael Wible 2