Correspondence 0001193125-23-019782 from Datum One Series Trust (CIK 0001806095)
Datum One Series Trust (CIK 0001806095)
Date: Jan. 31, 2023 · CIK: 0001806095 · Accession: 0001193125-23-019782
AI Filing Summary & Sentiment
File numbers found in text: 333-237048, 811-23556
Letter
VIA EDGAR CORRESPONDENCE United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. Re: Datum One Series Trust (the “Registrant”) File Nos. 333-237048 and 811-23556
Dear Ms. Lithotomos:
This letter provides the Registrant’s responses to a comment from the staff of the Securities and Exchange Commission (the “Staff”) that you provided by email on January 27, 2023 regarding Post-Effective Amendment No. 6 to the registration statement on Form N-1A of the Registrant (the “Registration Statement”) with respect to Polar Capital Emerging Market Ex-China Stars Fund (the “Fund”), a series of the Registrant. The Registration Statement was filed pursuant to Rule 485(a) under the Securities Act of 1933, as amended (“Securities Act”), on November 11, 2022 to register for public offer and sale the shares of the Fund.
The Staff also provided comments by telephone on January 5, 2023, which the Registrant responded to in a correspondence filing dated January 25, 2023. This letter reflects only the Registrant’s response the follow-up comment. For convenience of reference, the Staff comment has been summarized before the Registrant’s response. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.
1. Comment: Please add disclosure explaining how the Fund complies with Rule 35d-1 under the Investment Company Act of 1940 with respect to the term “Stars” in its name. The word “Stars” appears to modify the type of investments, and not a strategy.
Response: The Registrant confirms that the term “Stars,” as used in the Fund’s name, refers to the primary six facets of the portfolio management team’s bottom-up investment process, which, when included together in an illustration, create the shape of a star. Each of these pieces of the portfolio manager’s investment process are described in detail in the section titled ADDITIONAL INFORMATION ABOUT THE FUND—Investment Process for the Fund. The Registrant therefore believes that Rule 35d-1 does not warrant additional disclosure because the
term “Stars,” as used in the Fund’s name, suggests a strategy, not a type of investment, and therefore, Rule 35d-1 would not apply to the use of “Stars” in the Fund’s name.
* * * * * * * * * * * *
Please feel free to contact me at (617) 235-4636 to discuss any questions or comments you may have regarding the foregoing responses. Thank you for your assistance.
Sincerely,
/s/ Jessica Reece
Show Raw Text
CORRESP
1
filename1.htm
CORRESP
ROPES & GRAY LLP
PRUDENTIAL TOWER
800 BOYLSTON STREET
BOSTON, MA 02199-3600
WWW.ROPESGRAY.COM
January 31, 2023
Jessica L. Reece
T +1 617 235
4636
jessica.reece@ropesgray.com
VIA EDGAR CORRESPONDENCE
Ms. Valerie Lithotomos
United States Securities and
Exchange Commission
100 F Street, N.E.
Washington, D.C.
20549
Re: Datum One Series Trust (the “Registrant”)
File Nos. 333-237048 and 811-23556
Dear Ms. Lithotomos:
This letter provides the Registrant’s responses to a comment from the staff of the Securities and Exchange Commission (the “Staff”) that
you provided by email on January 27, 2023 regarding Post-Effective Amendment No. 6 to the registration statement on Form N-1A of the Registrant (the “Registration Statement”) with
respect to Polar Capital Emerging Market Ex-China Stars Fund (the “Fund”), a series of the Registrant. The Registration Statement was filed pursuant to Rule 485(a) under the Securities Act of
1933, as amended (“Securities Act”), on November 11, 2022 to register for public offer and sale the shares of the Fund.
The Staff also
provided comments by telephone on January 5, 2023, which the Registrant responded to in a correspondence filing dated January 25, 2023. This letter reflects only the Registrant’s response the
follow-up comment. For convenience of reference, the Staff comment has been summarized before the Registrant’s response. Capitalized terms not otherwise defined herein have the meanings ascribed to them
in the Registration Statement.
1.
Comment: Please add disclosure explaining how the Fund complies with Rule
35d-1 under the Investment Company Act of 1940 with respect to the term “Stars” in its name. The word “Stars” appears to modify the type of investments, and not a strategy.
Response: The Registrant confirms that the term “Stars,” as used in the Fund’s name,
refers to the primary six facets of the portfolio management team’s bottom-up investment process, which, when included together in an illustration, create the shape of a star. Each of these pieces of the
portfolio manager’s investment process are described in detail in the section titled ADDITIONAL INFORMATION ABOUT THE FUND—Investment Process for the Fund. The Registrant therefore believes that Rule
35d-1 does not warrant additional disclosure because the
1
term “Stars,” as used in the Fund’s name, suggests a strategy, not a type of investment, and therefore, Rule 35d-1 would not apply to
the use of “Stars” in the Fund’s name.
* * * * * * * * * * * *
Please feel free to contact me at (617) 235-4636 to discuss any questions or comments you may have regarding the
foregoing responses. Thank you for your assistance.
Sincerely,
/s/ Jessica Reece
Jessica Reece, Esq.
cc:
John M. Loder, Esq.
Barbara Nelligan
2