Correspondence 0000894189-25-001703 from Pacer Funds Trust (CIK 0001616668)
Pacer Funds Trust (CIK 0001616668)
Date: March 6, 2025 · CIK: 0001616668 · Accession: 0000894189-25-001703
AI Filing Summary & Sentiment
File numbers found in text: 333-201530, 811-23024
Letter
VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management Washington, D.C. 20549 Re: Pacer Funds Trust (the “Trust”) Pacer US Cash Cows 100 ETF Pacer US Small Cap Cash Cows 100 ETF (each, a “Fund” and together, the “Funds”) File Nos.: 333-201530, 811-23024
Dear Mr. Oh:
This correspondence responds to comments the Trust received from the Staff (the “Staff”) of the U.S. Securities and Exchange Commission with respect to Post-Effective Amendment No. 126 to the Trust’s Registration Statement on Form N-1A filed March 3, 2025 (the “Amendment”) with respect to the Funds, each a series of the Trust. For your convenience, the comments have been reproduced with a response following each comment. Capitalized terms not otherwise defined have the same meaning as in the Amendment. The Trust intends to make the requested revisions, as discussed below, in the definitive forms of Prospectus and Statement of Additional Information, pursuant to Rule 497(c) under the Securities Act of 1933, as amended.
1.Staff Comment: With respect to the paragraph describing the weightings of Index constituents in each Fund’s summary section, change the disclosure from “… (ii) a percentage value derived from 5% free float market capitalization ...” to “… a percentage equal to 5% of a company’s free float market capitalization ...”.
Response: The Trust has made the requested revisions.
2.Staff Comment: With respect to each Fund’s definition of “equity securities,” if a Fund invests in preferred stock, rights, warrants, or depositary receipts as part of its principal investment strategy, add corresponding principal risk disclosures.
Response: The Trust supplementally notes that the Funds do not invest in preferred stock, rights, warrants, or depositary receipts as part of their principal investment strategies, and therefore no corresponding risk disclosure has been added.
* * * * * *
If you have any questions or require further information, please contact Alyssa Bernard at U.S. Bank Global Fund Services, the Trust’s administrator, at alyssa.bernard@usbank.com or 414-516-1681.
Sincerely,
/s/ Joe M. Thomson
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CORRESP 1 filename1.htm Document 500 Chesterfield Parkway Malvern, Pennsylvania 19355 March 6, 2025 VIA EDGAR TRANSMISSION Mr. Sonny Oh United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549 Re: Pacer Funds Trust (the “Trust”) Pacer US Cash Cows 100 ETF Pacer US Small Cap Cash Cows 100 ETF (each, a “Fund” and together, the “Funds”) File Nos.: 333-201530, 811-23024 Dear Mr. Oh: This correspondence responds to comments the Trust received from the Staff (the “Staff”) of the U.S. Securities and Exchange Commission with respect to Post-Effective Amendment No. 126 to the Trust’s Registration Statement on Form N-1A filed March 3, 2025 (the “Amendment”) with respect to the Funds, each a series of the Trust. For your convenience, the comments have been reproduced with a response following each comment. Capitalized terms not otherwise defined have the same meaning as in the Amendment. The Trust intends to make the requested revisions, as discussed below, in the definitive forms of Prospectus and Statement of Additional Information, pursuant to Rule 497(c) under the Securities Act of 1933, as amended. 1.Staff Comment: With respect to the paragraph describing the weightings of Index constituents in each Fund’s summary section, change the disclosure from “… (ii) a percentage value derived from 5% free float market capitalization ...” to “… a percentage equal to 5% of a company’s free float market capitalization ...”. Response: The Trust has made the requested revisions. 2.Staff Comment: With respect to each Fund’s definition of “equity securities,” if a Fund invests in preferred stock, rights, warrants, or depositary receipts as part of its principal investment strategy, add corresponding principal risk disclosures. Response: The Trust supplementally notes that the Funds do not invest in preferred stock, rights, warrants, or depositary receipts as part of their principal investment strategies, and therefore no corresponding risk disclosure has been added. * * * * * * If you have any questions or require further information, please contact Alyssa Bernard at U.S. Bank Global Fund Services, the Trust’s administrator, at alyssa.bernard@usbank.com or 414-516-1681. Sincerely, /s/ Joe M. Thomson Joe M. Thomson President, Pacer Funds Trust