SEC Comment Letter for GraniteShares Gold Trust (BAR) (CIK 0001690437) (BAR) — Mar 31, 2022
GraniteShares Gold Trust (BAR) (CIK 0001690437)
Date: March 31, 2022 · CIK: 0001690437 · Accession: 0000000000-22-003543
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-263774
Letter
United States securities and exchange commission logo March 31, 2022 Benoit Autier Chief Accounting Officer GraniteShares Gold Trust 205 Hudson Street 7th Floor New York, NY 10013 Re:GraniteShares Gold Trust Registration Statement on Form S-3 Filed March 22, 2022 File No. 333-263774 Dear Mr. Autier: We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Form S-3 filed March 22. 2022 Prospectus Summary, page 2 1.Please prominently discuss here and in the Description of the Gold Industry on page 16 the impact of current geopolitical events on the gold market and the Trust. Please place this discussion in context by quantifying the relative contribution of Russia and Ukraine in the gold market. If you do not expect the impact to be material, please discuss why. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameBenoit Autier Comapany NameGraniteShares Gold Trust March 31, 2022 Page 2 FirstName LastName Benoit Autier GraniteShares Gold Trust March 31, 2022 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Jessica Livingston at 202-551-3448 or Sandra Hunter Berkheimer at 202- 551-3758 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Naveen Pogula
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United States securities and exchange commission logo
March 31, 2022
Benoit Autier
Chief Accounting Officer
GraniteShares Gold Trust
205 Hudson Street
7th Floor
New York, NY 10013
Re:GraniteShares Gold Trust
Registration Statement on Form S-3
Filed March 22, 2022
File No. 333-263774
Dear Mr. Autier:
We have limited our review of your registration statement to those issues we have
addressed in our comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-3 filed March 22. 2022
Prospectus Summary, page 2
1.Please prominently discuss here and in the Description of the Gold Industry on page 16
the impact of current geopolitical events on the gold market and the Trust. Please place
this discussion in context by quantifying the relative contribution of Russia and Ukraine in
the gold market. If you do not expect the impact to be material, please discuss why.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameBenoit Autier
Comapany NameGraniteShares Gold Trust
March 31, 2022 Page 2
FirstName LastName
Benoit Autier
GraniteShares Gold Trust
March 31, 2022
Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Jessica Livingston at 202-551-3448 or Sandra Hunter Berkheimer at 202-
551-3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Naveen Pogula