SEC Company Response from Krane Shares Trust (CIK 0001547576) — Oct 12, 2022
Krane Shares Trust (CIK 0001547576)
Date: Oct. 12, 2022 · CIK: 0001547576 · Accession: 0001829126-22-017888
AI Filing Summary & Sentiment
File numbers found in text: 333-180870, 811-22698
Letter
VIA EDGAR F Street, N.E. Washington, DC 20549 Re: KraneShares Trust (File Nos. 333-180870 and 811-22698) Responses to SEC Comments – Sarbanes-Oxley Review
Dear Mr. Burak:
On September 20, 2022, you provided oral comments on behalf of the SEC staff (“Staff”) regarding its examination of the KraneShares Trust’s (the “Registrant”) annual reports dated March 31, 2022. Your comments and the Registrant’s responses are set forth below.
1. Please update the investment objective included in the Management Discussion of Fund Performance (“MDFP”) for KraneShares Global Carbon Strategy ETF to match the investment objective included in KraneShares Global Carbon Strategy ETF’s prospectus.
RESPONSE: Going forward, the Registrant will ensure that the investment objective in the shareholder report matches the prospectus for KraneShares Global Carbon Strategy ETF.
2. The MDFPs for certain Funds should be enhanced to discuss the specific factors that impacted the Fund’s performance versus the performance of the Fund’s index especially in instances where the Fund’s performance materially differed from a Fund’s index. In particular, we note that KraneShares Bloomberg China Bond Inclusion Index ETF, KraneShares Emerging Markets Consumer Technology Index ETF, KraneShares MSCI China Clean Technology Index ETF, KraneShares Electric Vehicles and Future Mobility Index ETF, KraneShares Asia Pacific High Income Bond ETF, KraneShares CICC China 5G and Semiconductor Index ETF, and KraneShares China Innovation ETF had performance materially different from the index and did not discuss the specific factors that created such difference in the MDFP.
RESPONSE: Going forward, the Registrant will draft the MDFPs to discuss the specific factors that materially affected performance including those factors that contributed to performance materially differing from a Fund’s index.
* * * *
K&L GATES LLP
K STREET NW WASHINGTON DC 20006
T +1 202 778 9000 F +1 202 778 9100 klgates.com
If you have any questions regarding the matters discussed above, please feel free to call me at (202) 778-9475.
Sincerely,
/s/ Stacy L. Fuller
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CORRESP
1
filename1.htm
Stacy
L Fuller
Partner
stacy.fuller@klgates.com
T
+1 202 778 9475
F
+1 202 778 9100
October
12, 2022
VIA
EDGAR
Mr.
Tony Burak
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
DC 20549
Re:
KraneShares
Trust (File Nos. 333-180870 and 811-22698)
Responses
to SEC Comments – Sarbanes-Oxley Review
Dear
Mr. Burak:
On
September 20, 2022, you provided oral comments on behalf of the SEC staff (“Staff”) regarding its examination of the KraneShares
Trust’s (the “Registrant”) annual reports dated March 31, 2022. Your comments and the Registrant’s responses
are set forth below.
1. Please
update the investment objective included in the Management Discussion of Fund Performance
(“MDFP”) for KraneShares Global Carbon Strategy ETF to match the investment objective
included in KraneShares Global Carbon Strategy ETF’s prospectus.
RESPONSE:
Going forward, the Registrant will ensure that the investment objective in the shareholder report matches the prospectus for KraneShares
Global Carbon Strategy ETF.
2. The
MDFPs for certain Funds should be enhanced to discuss the specific factors that impacted
the Fund’s performance versus the performance of the Fund’s index especially
in instances where the Fund’s performance materially differed from a Fund’s index.
In particular, we note that KraneShares Bloomberg China Bond Inclusion Index ETF, KraneShares
Emerging Markets Consumer Technology Index ETF, KraneShares MSCI China Clean Technology Index
ETF, KraneShares Electric Vehicles and Future Mobility Index ETF, KraneShares Asia Pacific
High Income Bond ETF, KraneShares CICC China 5G and Semiconductor Index ETF, and KraneShares
China Innovation ETF had performance materially different from the index and did not discuss
the specific factors that created such difference in the MDFP.
RESPONSE:
Going forward, the Registrant will draft the MDFPs to discuss the specific factors that materially affected performance including those
factors that contributed to performance materially differing from a Fund’s index.
* * * *
K&L
GATES LLP
1601
K STREET NW WASHINGTON DC 20006
T
+1 202 778 9000 F +1 202 778 9100 klgates.com
If
you have any questions regarding the matters discussed above, please feel free to call me at (202) 778-9475.
Sincerely,
/s/ Stacy L. Fuller
Stacy L. Fuller
cc: Jonathan
Krane
Odette
Gafner
James
Maund
Jonathan
Shelon
Krane
Funds Advisors, LLC
Franklin
Na
K&L
Gates LLP
2