Correspondence 0001387131-23-009895 from Collaborative Investment Series Trust (CIK 0001719812)
Collaborative Investment Series Trust (CIK 0001719812)
Date: Aug. 16, 2023 · CIK: 0001719812 · Accession: 0001387131-23-009895
AI Filing Summary & Sentiment
File numbers found in text: 333-221072, 811-23306
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CORRESP
1
filename1.htm
August
11, 2023
Valerie
Lithotomos
Division
of Investment Management
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
Re: Collaborative
Investment Series Trust; File Nos. 811-23306 and 333-221072
Dear
Ms. Lithotomos:
On
June 2, 2023, Collaborative Investment Series Trust (the “Trust” or “Registrant”) filed a Registration
Statement under the Securities Act of 1933 and the Investment Company Act of 1940 (the “1940 Act”) on Form N-1A on
behalf of Goose Hollow Fixed Income ETF and Goose Hollow Hedged Equity ETF (the “Funds”).
The
Trust has revised the disclosure in the Fund’s prospectus and statement of additional information in response to comments
given by you via telephone to Matthew Tobin. Those comments are summarized below, with corresponding responses following each
comment, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Capitalized
terms used but not otherwise defined herein have the meanings ascribed to them in the document to which the applicable comment
relates.
Please
note that the Fund names have been revised from “Goose Hollow Fixed Income ETF” to “Goose Hollow Multi-Strategy
Income ETF” and from “Goose Hollow Hedged Equity ETF” to “Goose Hollow Enhanced Equity ETF.”
Comment
1. Please apply comments to other applicable disclosures as needed.
Response:
The revisions will be applied as needed throughout the amendment.
Comment
2. The Fees and Expenses of the Fund table for the Goose Hollow Fixed Income ETF is incomplete. Please provide the completed
Fees and Expenses of the Fund table for Goose Hollow Fixed Income ETF with adequate opportunity for review (at least five (5)
business days prior to effective date).
Response:
Please see the completed fee table below:
Annual
Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management
Fees
0.60%
Distribution
and/or Service (12b-1) Fees
0.00%
Other
Expenses(1)
0.79%
Acquired
Fund Fees and Expenses(2)
0.20%
Total
Annual Fund Operating Expenses
1.59%
Fee
Waiver and Reimbursement (3)
0.39%
Total
Annual Fund Operating Expenses After Fee Waiver
1.20%
Page
2
(1)
Estimated for the current fiscal period.
(2)
Acquired Fund Fees and Expenses, which are estimated for the Fund’s current fiscal year, are the indirect costs of investing
in other investment companies. The operating expenses in this fee table will not correlate to the expense ratio in the Fund's
financial highlights because the financial statements include only the direct operating expenses incurred by the Fund.
(3)
The adviser has contractually agreed to reduce its fees and to reimburse expenses, at least through January 31, 2025 to ensure
that Net Annual Fund Operating Expenses (exclusive of any (i) front-end or contingent deferred loads, (ii) brokerage fees and
commissions, (iii) acquired fund fees and expenses, (iv) fees and expenses associated with instruments in other collective investment
vehicles or derivative instruments (including for example options and swap fees and expenses); (v) borrowing costs (such as interest
and dividend expense on securities sold short), (vi) taxes, (vii) other fees related to underlying investments, (such as option
fees and expenses or swap fees and expenses); or (viii) extraordinary expenses such as litigation (which may include indemnification
of Fund officers and trustees or contractual indemnification of Fund service providers (other than the advisor)) will not exceed
1.00%. Fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years on a rolling three-year
basis (within the three years after the fees have been waived or reimbursed) if such recoupment can be achieved within the foregoing
expense limits or the expense limits in place at the time of recoupment. Fee waiver and reimbursement arrangements can decrease
the Fund’s expenses and boost its performance. This expense limitation agreement may be terminated at any time, by the Board
upon sixty days written notice to the adviser.
Comment
3. Comment 2 on the Fees and Expenses of the Fund table for the Goose Hollow Fixed Income ETF states: “Fee waiver and
reimbursement arrangements can decrease the Fund’s expenses and boost its performance.” It does not make sense why
performance would be boosted by fee waiver and reimbursement arrangements. Please provide a supplementary explanation what is
meant by this statement. Alternatively, is there is no reason why this statement boosts performance, please remove.
Response:
Because the operating expense limitation is in place, expenses would be lower than they otherwise would resulting in better
performance.
Comment
4. Since the Fund is investing in foreign securities, please add investing in emerging markets as a risk factor.
Response:
The Fund does not intend to invest in emerging market securities as a principal investment strategy. Accordingly, no risk
disclosure has been added.
Page 3
Comment
5. The Fees and Expenses of the Fund table for the Goose Hollow Hedged Equity ETF is incomplete. Please provide the completed
Fees and Expenses of the Fund table for Goose Hollow Hedged Equity ETF with adequate opportunity for review (at least five (5)
business days prior to effective date).
Response:
Please see the completed fee table below:
Annual
Fund Operating Expenses
(expenses that you pay each year as a percentage of the value of your investment)
Management
Fees
0.85%
Distribution
and/or Service (12b-1) Fees
0.00%
Other
Expenses(1)
0.79%
Acquired
Fund Fees and Expenses(2)
0.28%
Total
Annual Fund Operating Expenses
1.92%
Fee
Waiver and Reimbursement (3)
0.64%
Total
Annual Fund Operating Expenses After Fee Waiver
1.28%
(1)
Estimated for the current fiscal period.
(2)
Acquired Fund Fees and Expenses, which are estimated for the Fund’s current fiscal period, are the indirect costs of investing
in other investment companies. The operating expenses in this fee table will not correlate to the expense ratio in the Fund's
financial highlights because the financial statements include only the direct operating expenses incurred by the Fund.
(3)
The adviser has contractually agreed to reduce its fees and to reimburse expenses, at least through January 31, 2025 to ensure
that Net Annual Fund Operating Expenses (exclusive of any (i) front-end or contingent deferred loads, (ii) brokerage fees and
commissions, (iii) acquired fund fees and expenses, (iv) fees and expenses associated with instruments in other collective investment
vehicles or derivative instruments (including for example options and swap fees and expenses); (v) borrowing costs (such as interest
and dividend expense on securities sold short), (vi) taxes, (vii) other fees related to underlying investments, (such as option
fees and expenses or swap fees and expenses); or (viii) extraordinary expenses such as litigation (which may include indemnification
of Fund officers and trustees or contractual indemnification of Fund service providers (other than the advisor)) will not exceed
1.00%. Fee waivers and expense reimbursements are subject to possible recoupment from the Fund in future years on a rolling three-year
basis (within the three years after the fees have been waived or reimbursed) if such recoupment can be achieved within the foregoing
expense limits or the expense limits in place at the time of recoupment. Fee waiver and reimbursement arrangements can decrease
the Fund’s expenses and boost its performance. This expense limitation agreement may be terminated at any time, by the Board
upon sixty days written notice to the adviser.
Page 4
Comment
6. Comment 2 on the Fees and Expenses of the Fund table for the Goose Hollow Hedged Equity ETF states: “Fee waiver and
reimbursement arrangements can decrease the Fund’s expenses and boost its performance.” It does not make sense why
performance would be boosted by fee waiver and reimbursement arrangements. Please provide a supplementary explanation what is
meant by this statement. Alternatively, is there is no reason why this statement boosts performance, please remove.
Response:
Because the operating expense limitation is in place, expenses would be lower than they otherwise would resulting in better
performance.
Comment
7. Hedging appears to be a small percentage of the Goose Hollow Hedged Equity ETF since it is limited to twenty percent (20%)
of the investment vehicle. In order to comply with Rule 35d-1 please state that hedging is a strategy in order to comply with
the rule.
Response:
The Registrant has decided to change the Fund’s name to “Goose Hollow Enhanced Equity ETF.” The adviser
will seek to enhance to overall returns of the Fund through its futures/option strategy.
Comment
8. Please add cyber security risk under the Principal Risk sections for both funds.
Response:
The Registrant declines to make the requested revision.
Comment
9. Please add ticker symbols for both funds.
Response:
The symbols have been added.
* * * * *
If
you have any questions or additional comments, please call the undersigned at 614-469-3353.
Very
truly yours,
/s/ Andrew Davalla
Andrew Davalla