Correspondence 0001398344-25-009813 from IMPAX FUNDS SERIES TRUST III (CIK 0001598735)
IMPAX FUNDS SERIES TRUST III (CIK 0001598735)
Date: May 19, 2025 · CIK: 0001598735 · Accession: 0001398344-25-009813
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-194601, 811-02064, 811-22935
Letter
Division of Investment Management 100 F Street, NE Washington, DC 20549 Attention: Ken Ellington Re: Impax Funds Series Trust I (Registration Nos. 002-38679, 811-02064) and Impax Funds Series Trust III (Registration Nos. 333-194601, 811-22935) (the “Registrants”)
Dear Mr. Ellington,
We are writing to respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that you provided telephonically on May 14, 2025 in connection with the Registrants’ annual financial statements and Form N-CSR (together, the “Annual Report”) filed on March 6, 2025. The Staff’s comments are summarized below, and each is followed by our response. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Annual Report.
1. Comment. The Staff notes that the Table of Contents lists Impax International Sustainable Economy Fund’s Schedule of Investments twice and does not list Impax Global Sustainable Infrastructure Fund’s Schedule of Investments. Please confirm that the Table of Contents will be updated in future N-CSR filings.
Response. The Registrants will update the Table of Contents in future N-CSR filings.
2. Comment. In future N-CSR filings, please include disclosure responsive to Items 4(i) and (j), even if those items are not applicable to the Registrants.
Response. The Registrants will include disclosure responsive to Items 4(i) and (j) in future N-CSR filings.
* * * * *
We hope that the foregoing responses adequately address the Staff’s comments. Should you have any further questions or comments, please do not hesitate to contact me at the number referenced above.
Very truly yours,
/s/ Jimena Acuña Smith
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ROPES & GRAY LLP
THREE EMBARCADERO CENTER
SAN FRANCISCO, CA 94111-4006
WWW.ROPESGRAY.COM
Jimena Acuña Smith
T +1 415 315 2306
jimena.smith@ropesgray.com
May 19, 2025
BY EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Attention: Ken Ellington
Re: Impax Funds Series Trust I (Registration Nos. 002-38679, 811-02064) and Impax Funds Series Trust III (Registration
Nos. 333-194601, 811-22935) (the “Registrants”)
Dear Mr. Ellington,
We are writing to respond to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) that you provided telephonically on May 14, 2025 in connection
with the Registrants’ annual financial statements and Form N-CSR (together, the “Annual Report”) filed on March
6, 2025. The Staff’s comments are summarized below, and each is followed by our response. Capitalized terms not otherwise defined
herein have the meanings ascribed to them in the Annual Report.
1. Comment. The Staff notes that the Table of Contents lists Impax International Sustainable Economy Fund’s Schedule of
Investments twice and does not list Impax Global Sustainable Infrastructure Fund’s Schedule of Investments. Please confirm that
the Table of Contents will be updated in future N-CSR filings.
Response. The Registrants will update the Table
of Contents in future N-CSR filings.
2. Comment. In future N-CSR filings, please include disclosure responsive to Items 4(i) and (j), even if those items are not applicable
to the Registrants.
Response. The Registrants will include disclosure
responsive to Items 4(i) and (j) in future N-CSR filings.
* * * * *
We hope that the foregoing responses adequately address the Staff’s
comments. Should you have any further questions or comments, please do not hesitate to contact me at the number referenced above.
Very truly yours,
/s/ Jimena Acuña Smith
Jimena Acuña Smith