Correspondence 0001213900-24-018717 from VanEck Merk Gold Trust (OUNZ) (CIK 0001546652) (OUNZ)
VanEck Merk Gold Trust (OUNZ) (CIK 0001546652)
Date: Feb. 29, 2024 · CIK: 0001546652 · Accession: 0001213900-24-018717
AI Filing Summary & Sentiment
File numbers found in text: 001-36459
Referenced dates: January 24, 2024
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CORRESP 1 filename1.htm February 29, 2024 Shoshannah Katz D 949-623-3545 Shoshannah.katz@klgates.com By EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, DC 20549 Re: VanEck Merk Gold Trust Form 10-K for the Fiscal Year Ended January 31, 2023 File No. 001-36459 Ladies and Gentlemen: We are submitting this letter on behalf of VanEck Merk Gold Trust (the “Trust”), in response to a comment from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter dated January 24, 2024 relating to the Trust’s Annual Report on Form 10-K for the fiscal year ended January 31, 2023, filed with the Commission via EDGAR on April 13, 2023 (the “Form 10-K”). For convenience, we have set forth below, in italicized, bold type, the written comment provided in the Staff’ letter to the Trust dated January 24, 2024. The response of the Trust to the Comment is set forth immediately following the comment. 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. In response to the Staff’s comment, the Trust has filed an amendment to the Form 10-K to include the audit report of BBD, LLP covering the financial statements noted by the Staff. * * * K&L Gates LLP TWELFTH FLOOR, 1 PARK PLAZA, IRVINE, CA 92614 T +1 949 253 0900 F +1 949 253 0902 klgates.com Please do not hesitate to contact me at (949) 623-3545, or in my absence, Jason C. Dreibelbis at (949) 623-3543, if you have any questions or would like additional information regarding this matter. Very truly yours, /s/ Shoshannah Katz Shoshannah Katz cc: Axel Merk, Merk Investments LLC Daniel Lucas, Merk Investments LLC Jason C. Dreibelbis, K&L Gates LLP