SEC Comment Letter for Wilshire wShares Enhanced Gold Trust (CIK 0001799858) — Jan 27, 2021
Wilshire wShares Enhanced Gold Trust (CIK 0001799858)
Date: Jan. 27, 2021 · CIK: 0001799858 · Accession: 0000000000-21-001008
AI Filing Summary & Sentiment
File numbers found in text: 333-235913
Referenced dates: January 11, 2021
Letter
United States securities and exchange commission logo January 27, 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 Response Letter dated January 11, 2021 File No. 333-235913 Dear Mr. Cai: We have reviewed your response letter 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 January 5, 2021 letter. Response Letter dated January 11, 2021 Description of the Index, page 41 1.We note your response to our prior comment 2. Please revise to disclose how the realized volatility of the LBMA Gold Price PM and the S&P 500® Index are calculated and, if applicable, where such realized volatility data may be publicly available, and whether there are any limits or risks to using publicly available realized volatility data. Please also tell us the extent to which investors should expect the actual realized volatility percentages to fall outside the range of outcomes covered by the hypothetical weighting matrix for the Physical Gold Component and the impact on outcomes if they do so, and revise your prospectus as appropriate.
FirstName LastNameWilliam Cai Comapany NameWilshire Phoenix Funds LLC January 27, 2021 Page 2 FirstName LastName William Cai Wilshire Phoenix Funds LLC January 27, 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 27, 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
Response Letter dated January 11, 2021
File No. 333-235913
Dear Mr. Cai:
We have reviewed your response letter 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 January 5, 2021 letter.
Response Letter dated January 11, 2021
Description of the Index, page 41
1.We note your response to our prior comment 2. Please revise to disclose how the realized
volatility of the LBMA Gold Price PM and the S&P 500® Index are calculated and, if
applicable, where such realized volatility data may be publicly available, and whether
there are any limits or risks to using publicly available realized volatility data. Please also
tell us the extent to which investors should expect the actual realized volatility percentages
to fall outside the range of outcomes covered by the hypothetical weighting matrix for the
Physical Gold Component and the impact on outcomes if they do so, and revise your
prospectus as appropriate.
FirstName LastNameWilliam Cai
Comapany NameWilshire Phoenix Funds LLC
January 27, 2021 Page 2
FirstName LastName
William Cai
Wilshire Phoenix Funds LLC
January 27, 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