Correspondence 0000894189-25-002528 from Pacer Funds Trust (CIK 0001616668)
Pacer Funds Trust (CIK 0001616668)
Date: April 18, 2025 · CIK: 0001616668 · Accession: 0000894189-25-002528
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 S&P 500 Quality FCF Aristocrats ETF (the “Fund”) File Nos.: 333-201530, 811-23024
Dear Mr. Oh:
This correspondence responds to additional comments the Trust received from the Staff (the “Staff”) of the U.S. Securities and Exchange Commission on April 17, 2025 with respect to Post-Effective Amendment No. 124 to the Trust’s Registration Statement on Form N-1A filed February 7, 2025 (the “Amendment”) with respect to the Fund, 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.
1.Staff Comment: Please revise the Fund’s definition of “equity securities” as follows: The Fund defines “equity securities” to mean common stocks, and may include preferred stocks, rights, warrants, and depositary receipts.
Response: The requested change has been made.
2.Staff Comment: In the Investment Limitations section of the Statement of Additional Information, with respect to the second non-fundamental investment restriction, please state the name of the index, rather than using a defined term.
Response: The Trust has revised the second non-fundamental investment restriction as follows: “Under normal circumstances, at least 80% of the Fund’s net assets (plus any borrowings for investment purposes) will be invested in equity securities that are the component securities of the S&P 500 Quality FCF Aristocrats Index.”
* * *
If you have any questions or require further information, please contact me at alyssa.bernard@usbank.com or (414) 516-1681.
Sincerely,
/s/ Alyssa M. Bernard
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CORRESP 1 filename1.htm Document Pacer Funds Trust 500 Chesterfield Parkway Malvern, Pennsylvania 19355 April 18, 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 S&P 500 Quality FCF Aristocrats ETF (the “Fund”) File Nos.: 333-201530, 811-23024 Dear Mr. Oh: This correspondence responds to additional comments the Trust received from the Staff (the “Staff”) of the U.S. Securities and Exchange Commission on April 17, 2025 with respect to Post-Effective Amendment No. 124 to the Trust’s Registration Statement on Form N-1A filed February 7, 2025 (the “Amendment”) with respect to the Fund, 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. 1.Staff Comment: Please revise the Fund’s definition of “equity securities” as follows: The Fund defines “equity securities” to mean common stocks, and may include preferred stocks, rights, warrants, and depositary receipts. Response: The requested change has been made. 2.Staff Comment: In the Investment Limitations section of the Statement of Additional Information, with respect to the second non-fundamental investment restriction, please state the name of the index, rather than using a defined term. Response: The Trust has revised the second non-fundamental investment restriction as follows: “Under normal circumstances, at least 80% of the Fund’s net assets (plus any borrowings for investment purposes) will be invested in equity securities that are the component securities of the S&P 500 Quality FCF Aristocrats Index.” * * * If you have any questions or require further information, please contact me at alyssa.bernard@usbank.com or (414) 516-1681. Sincerely, /s/ Alyssa M. Bernard Alyssa M. Bernard Vice President U.S. Bank Global Fund Services as Administrator for the Trust 1