SEC Comment Letter 0000000000-24-000948 to VanEck Merk Gold Trust (OUNZ) (CIK 0001546652) (OUNZ)
VanEck Merk Gold Trust (OUNZ) (CIK 0001546652)
Date: Jan. 24, 2024 · CIK: 0001546652 · Accession: 0000000000-24-000948
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File numbers found in text: 001-36459
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United States securities and exchange commission logo
January 24, 2024
Axel Merk
President and Chief Investment Officer
VanEck Merk Gold Trust
c/o Merk Investments LLC
1150 Chesnut Street
Menlo Park, California 94025
Re:VanEck Merk Gold Trust
Form 10-K for the Fiscal Year Ended January 31, 2023
File No. 001-36459
Dear Axel Merk:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended January 31, 2023
Financial Statements
Report of Independent Registered Public Accounting Firm, page F-2
1.We note that you did not include an audit report covering the statement of assets and
liabilities, including the schedule of investment, as of January 31, 2022, and the related
statements of operations and changes in net assets for the years ended January 31, 2022
and 2021, and the financial highlights for the years ended January 31, 2022, 2021, 2020,
and 2019. We further note the disclosure in the report that these financial statements were
audited by other auditors. Please amend to include an audit report covering these financial
statements.
FirstName LastNameAxel Merk
Comapany NameVanEck Merk Gold Trust
January 24, 2024 Page 2
FirstName LastName
Axel Merk
VanEck Merk Gold Trust
January 24, 2024
Page 2
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.
Please contact Kate Tillan at 202-551-3604 or Mark Brunhofer at 202-551-3638 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets