SEC Comment Letter for Wilshire wShares Enhanced Gold Trust (CIK 0001799858) — Jan 5, 2021
Wilshire wShares Enhanced Gold Trust (CIK 0001799858)
Date: Jan. 5, 2021 · CIK: 0001799858 · Accession: 0000000000-21-000102
AI Filing Summary & Sentiment
File numbers found in text: 333-235913
Letter
United States securities and exchange commission logo January 5, 2021 William Cai Partner Wilshire Phoenix Funds LLC 2 Park Avenue, 20th Floor New York, NY 10016 Re:Wilshire wShares Enhanced Gold Trust Amendment No. 4 to Registration Statement on Form S-1 Filed December 18, 2020 File No. 333-235913 Dear Mr. Cai: We have reviewed your amended registration statement and have the following 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. Unless we note otherwise, our references to prior comments are to comments in our December 7, 2020 letter. Amendment No. 4 to Registration Statement on Form S-1 Description of the Index, page 41 1.We note your response to our prior comment 1. Please revise your disclosure to more clearly make the connection between reducing the risk-profile typically associated with the purchase of gold and making component weighting adjustments based on the volatility of the LBMA Gold Price PM and the volatility of the S&P 500® Index. To the extent the reasoning that supports this connection is based on historical data or observations, please revise to clarify accordingly. 2.We note your response to our prior comment 2 and we reissue. It does not appear that you have provided a materially complete description of the operation of the Index. Please revise to disclose the methodology.
FirstName LastNameWilliam Cai Comapany NameWilshire Phoenix Funds LLC January 5, 2021 Page 2 FirstName LastName William Cai Wilshire Phoenix Funds LLC January 5, 2021 Page 2 You may contact William Schroeder, Staff Accountant, at (202) 551-3294 or Michael Volley, Staff Accountant, at (202) 551-3437 if you have questions regarding comments on the financial statements and related matters. Please contact David Lin, Staff Attorney, at (202) 551- 3552 or Justin Dobbie, Legal Branch Chief, at (202) 551-3469 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
January 5, 2021
William Cai
Partner
Wilshire Phoenix Funds LLC
2 Park Avenue, 20th Floor
New York, NY 10016
Re:Wilshire wShares Enhanced Gold Trust
Amendment No. 4 to Registration Statement on Form S-1
Filed December 18, 2020
File No. 333-235913
Dear Mr. Cai:
We have reviewed your amended registration statement and have the following
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. Unless we note
otherwise, our references to prior comments are to comments in our December 7, 2020 letter.
Amendment No. 4 to Registration Statement on Form S-1
Description of the Index, page 41
1.We note your response to our prior comment 1. Please revise your disclosure to more
clearly make the connection between reducing the risk-profile typically associated with
the purchase of gold and making component weighting adjustments based on the volatility
of the LBMA Gold Price PM and the volatility of the S&P 500® Index. To the extent the
reasoning that supports this connection is based on historical data or observations, please
revise to clarify accordingly.
2.We note your response to our prior comment 2 and we reissue. It does not appear that you
have provided a materially complete description of the operation of the Index. Please
revise to disclose the methodology.
FirstName LastNameWilliam Cai
Comapany NameWilshire Phoenix Funds LLC
January 5, 2021 Page 2
FirstName LastName
William Cai
Wilshire Phoenix Funds LLC
January 5, 2021
Page 2
You may contact William Schroeder, Staff Accountant, at (202) 551-3294 or Michael
Volley, Staff Accountant, at (202) 551-3437 if you have questions regarding comments on the
financial statements and related matters. Please contact David Lin, Staff Attorney, at (202) 551-
3552 or Justin Dobbie, Legal Branch Chief, at (202) 551-3469 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance