Correspondence 0000894189-24-007617 from FundX Investment Trust (CIK 0001602508)
FundX Investment Trust (CIK 0001602508)
Date: Dec. 26, 2024 · CIK: 0001602508 · Accession: 0000894189-24-007617
AI Filing Summary & Sentiment
File numbers found in text: 333-194652, 811-22951
Letter
VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management 100 "F" Street N.E. Washington, D.C. 20549 Re: FundX Investment Trust (the “Trust”) SEC File Numbers: 333-194652; 811-22951
Dear Mr. Ellington:
This correspondence is being filed in response to comments you provided via telephone on December 20, 2024 in connection with the SEC Staff’s Sarbanes-Oxley Act of 2002, as amended, review of the Trust’s Form N-CSR filing, as filed with the Commission on December 6, 2024 (the “Annual Report”), for its Funds.
For your convenience in reviewing the Trust’s response, your comment is briefly summarized below, immediately followed by the Trust’s response.
Comment 1: The staff notes that in the cumulative performance graph for the Conservative ETF a blended index is presented. In accordance with Item 4(b)(2)(iii) of Form N-1A and instruction six to item 27A(d)(2) please explain how the chosen benchmark index is deemed to be an appropriate board-based securities market index?
Response: The Trust confirms that future Form N-CSR filings for the Conservative ETF will include a line graph for the S&P 500 Index and another for the Bloomberg Aggregate Bond Index in the cumulative performance graph.
I trust that the above responses and revisions adequately address your comments. If you have any questions, need any additional information or would like any clarification, please contact me at (415) 248-8366.
Sincerely,
/s/ Jeff Smith
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CORRESP 1 filename1.htm Document FundX Investment Trust 101 Montgomery Street, Suite 2400 San Francisco, California 94104-3008 December 26, 2024 VIA EDGAR TRANSMISSION Mr. Kenneth Ellington, Staff Accountant United States Securities and Exchange Commission Division of Investment Management 100 "F" Street N.E. Washington, D.C. 20549 Re: FundX Investment Trust (the “Trust”) SEC File Numbers: 333-194652; 811-22951 Dear Mr. Ellington: This correspondence is being filed in response to comments you provided via telephone on December 20, 2024 in connection with the SEC Staff’s Sarbanes-Oxley Act of 2002, as amended, review of the Trust’s Form N-CSR filing, as filed with the Commission on December 6, 2024 (the “Annual Report”), for its Funds. For your convenience in reviewing the Trust’s response, your comment is briefly summarized below, immediately followed by the Trust’s response. Comment 1: The staff notes that in the cumulative performance graph for the Conservative ETF a blended index is presented. In accordance with Item 4(b)(2)(iii) of Form N-1A and instruction six to item 27A(d)(2) please explain how the chosen benchmark index is deemed to be an appropriate board-based securities market index? Response: The Trust confirms that future Form N-CSR filings for the Conservative ETF will include a line graph for the S&P 500 Index and another for the Bloomberg Aggregate Bond Index in the cumulative performance graph. I trust that the above responses and revisions adequately address your comments. If you have any questions, need any additional information or would like any clarification, please contact me at (415) 248-8366. Sincerely, /s/ Jeff Smith Jeff Smith President, FundX Investment Trust