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SEC Company Response from GraniteShares Gold Trust (BAR) (CIK 0001690437) (BAR) — Sep 11, 2017

GraniteShares Gold Trust (BAR) (CIK 0001690437)
Date: Sept. 11, 2017 · CIK: 0001690437 · Accession: 0001387131-17-004618

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File numbers found in text: 333-219319

Date
July 31, 2017
Author
Tom
Form
CORRESP
Company
GraniteShares Gold Trust (BAR) (CIK 0001690437)

Letter

From:

Conner, W. Thomas

Sent:

Monday, July 31, 2017 11:41 AM

To:

Patel, Rahul

Cc:

Lewis, Luisa M.; Gonzalez, Victor J.

Subject:

[FS#22317001] GraniteShares Gold Trust (File No. 333-219319) Fact Sheet

Rahul:

In your correspondence with GraniteShares Gold Trust dated June 2, 2017, Comment 3 asked that to the extent the registrant uses a fact sheet, it provide the staff with the fact sheet when it becomes available.

Please find attached the current fact sheet as proposed to be used. Please let us know if the fact sheet also needs to be filed on EDGAR.

Best regards,
Tom

Show Raw Text
CORRESP
1
filename1.htm

From:

Conner, W. Thomas

Sent:

Monday, July 31, 2017 11:41 AM

To:

Patel, Rahul

Cc:

Lewis, Luisa M.; Gonzalez, Victor J.

Subject:

[FS#22317001] GraniteShares Gold Trust (File No.
333-219319) Fact Sheet

Rahul:

In your correspondence with GraniteShares Gold Trust
dated June 2, 2017, Comment 3 asked that to the extent the registrant uses a fact sheet, it provide the staff with the fact sheet
when it becomes available.

Please find attached the current fact sheet as proposed
to be used. Please let us know if the fact sheet also needs to be filed on EDGAR.

Best regards,

Tom

GraniteShares
Trust

BAR

INVESTMENT
OBJECTIVE

The GraniteShares
Gold Trust is designed to seek the performance of the price of gold less trust expenses.

    Physically backed. The trust holds
    physical gold bars in a secure vault

    Transparent bar list posted daily

    Cost effective access to physical
    gold

    GraniteShares Gold Trust

    Trust CHARACTERISTICS
    As of 6/30/2017

    PRODUCT
    TICKER
    BAR

    AUM
    TBD

    SPONSOR
    FEE
    0.20%

    INCEPTION
    DATE
    TBD

    BENCHMARK
    GOLD

    CUSIP
    TBD

    EXCHANGE
    NYSE
    Arca

    IOPV
    TICKER
    BARIV

    REPLICATION
    PHYSICAL

    VAULT
    LOCATION
    LONDON

    CUSTODIAN
    ICBC
    STANDARD BANK PLC

    VAULT
    INSPECTOR
    INSPECTORATE
    INT’L

    VAULT
    INSPECTION FREQUENCY
    TWICE
    ANNUALLY

    TRUSTEE
    BNY
    MELLON

PERFORMANCE
AS OF TBC

    1 month
    3 month
    YTD
    1 Year
    3 Year
    Since Inception

    BAR NAV

    BAR Market Price

    Gold
    -1.89%
    -0.21%
    8.41%
    -05.94%
    -5.53%

Performance
As of TBC data quoted represents past Performance As of TBC and is no guarantee of future results. Current Performance As of
TBC may be lower or higher than the Performance As of TBC data quoted. Investment return and principal value will fluctuate
so that an investor’s shares, when redeemed, may be worth more or less than original cost. Returns less than one year
are not annualized. NAV prices are used to calculate market price Performance As of TBC prior to the date when the Trust
first traded on the New York Stock Exchange. Market Performance As of TBC is determined using the bid/ask midpoint at 4:00pm
Eastern time, when the NAV is typically calculated. Market Performance As of TBC does not represent the returns you would
receive if you traded shares at other times. For the Trust’s most recent month end Performance As of TBC, please call
1(844) 476-8747 or visit www. graniteshares.com.

COMMODITY
SECTOR BREAKDOWN:

    ■  Physical
    Gold
    100%

    30 Vesey Street,

    9th Floor, New York,

NY 10007
    844-476-8747

    info@graniteshares.com

    graniteshares.com

    BAR
    GraniteShares Trust

DISCLAIMER

This material must be preceded or accompanied
by a prospectus. Please read the prospectus carefully before investing or sending money. To obtain a prospectus visit the link
www.graniteshares.com/Trusts

Shares of the Trust are not insured by the Federal
Deposit Insurance Corporation (“FDIC”), may lose value and have no bank guarantee.

BAR is not a mutual fund or any other type of
Investment Company within the meaning of the Investment Company Act of 1940, as amended, and is not subject to regulation thereunder.

The Trust is not a commodity pool for purposes
of the Commodity Exchange Act of 1936, as amended.

The Trust is recently formed and has a limited
history of operations. There can be no assurances that its objective will be met.

Trust shares trade like stocks, are subject to
investment risk and will fluctuate in market value. The value of Trust shares relates directly to the value of the gold held by
the Trust (less its expenses), and fluctuations in the price of gold could materially and adversely affect an investment in the
shares. The price received upon the sale of the shares, which trade at market price, may be more or less than the value of the
gold represented by them. Shares of the Trust are bought and sold at market price. Brokerage commissions will reduce returns.

Market Price: The current price at which shares
are bought and sold. Market returns are based upon the last trade price.

NAV: The dollar value of a single share, based
on the value of the underlying assets of the Trust minus its liabilities, divided by the number of shares outstanding. Calculated
at the end of each business day.

Physical Replication: The Trust owns the underlying
assets of the index whether they are stocks, bonds, or in this case, gold bars.

The objective of the Trust is for the value of
the Shares to reflect, at any given time, the value of the assets owned by the Trust at that time less the Trust’s accrued
expenses and liabilities as of that time. The Shares are intended to constitute a simple and cost-effective means of making an
investment similar to an investment in gold. An investment in allocated physical gold bullion requires expensive and sometimes
complicated arrangements in connection with the assay, transportation and warehousing of the metal. Traditionally, such expense
and complications have resulted in investments in physical gold bullion being efficient only in amounts beyond the reach of many
investors. The Shares have been designed to remove the obstacles represented by the expense and complications involved in an investment
in physical gold bullion, while at the same time having an intrinsic value that reflects, at any given time, the price of the assets
owned by the Trust at such time less the Trust expenses and liabilities. Although the Shares are not the exact equivalent of an
investment in gold, they provide investors with an alternative that allows a level of participation in the gold market through
the securities market.

The Sponsor of the Trust is GraniteShares LLC.

THE TRUST IS DISTRIBUTED BY FORESIDE FUND SERVICES,
LLC. GRANITESHARES IS NOT AFFILIATED WITH FORESIDE FUND SERVICES, LLC

Trust RISKS

Investing in the shares involves significant
risks, including possible loss of principal. You could lose money on an investment in the Trust. For a more complete discussion
of risk factors relative to the Trust, carefully read the prospectus.

Shares are created to reflect the price of the
gold held by the Trust, the market price of the shares will be as unpredictable as the price of gold has historically been. This
creates the potential for losses, regardless of whether you hold Shares for the short-, mid- or long-term.

The amount of gold represented by each share
will decrease over the life of the Trust due to the sales of gold necessary to pay the Sponsor’s Fee and Trust expenses.
Without increases in the price of gold sufficient to compensate for that decrease, the price of the Shares will also decline and
you will lose money on your investment in shares.

The Trust is a passive investment vehicle. The
price received upon the sale of shares may be less than the value of the gold represented by them.

The Trust is not a diversified investment, it
may be more volatile than other investments.

The Trust may be forced to sell gold earlier
than anticipated if expenses are higher than expected.

The Sponsor has no history of operating an investment
vehicle like the Trust, its experience may be inadequate or unsuitable to manage the Trust.

Gold Benchmark - LBMA Gold Price PM. ICE Benchmark
Administration (IBA) is the administrator for the LBMA Gold Price 2017 GraniteShares Inc. All rights reserved. GraniteShares,
GraniteShares Trusts, and the GraniteShares logo are registered and unregistered trademarks of GraniteShares Inc., in the United
States and elsewhere. All other marks are the property of their respective owners.

    30 Vesey Street,
    844-476-8747

    9th Floor, New York,
    info@graniteshares.com

    NY 10007
    graniteshares.com