Correspondence 0001213900-25-014244 from Strategic Trust (CIK 0001873280)
Strategic Trust (CIK 0001873280)
Date: Feb. 14, 2025 · CIK: 0001873280 · Accession: 0001213900-25-014244
AI Filing Summary & Sentiment
File numbers found in text: 333-258490, 811-27323
Letter
Via EDGAR Division of Investment Management 100 F Street, NE Washington, DC 20549 Re: Strategic Trust File Nos.: 333-258490, 811-27323
Dear Ms. Lithotomos:
On behalf of Strategic Trust (the “Trust” or the “Registrant”) and its series, Daily Delta N100 Downside Option Strategy ETF, Daily Delta N100 Upside Option Strategy ETF, Daily Delta R2000 Downside Option Strategy ETF, Daily Delta R2000 Upside Option Strategy ETF, Daily Delta S500 Downside Option Strategy ETF and Daily Delta S500 Upside Option Strategy ETF (each and “Fund” and, together, the “Funds”), set forth below are the Registrant’s responses to the comments provided by the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) on February 13, 2025 regarding the Registrant’s Post-Effective Amendment No. 25 to the Registrant’s registration statement on Form N-1A (the “Amendment”). The Staff’s comments are set forth below and are followed by the Company’s responses.
1. With respect to each Fund, please adopt an 80% investment policy referencing the Fund’s respective index or explain why such a policy is not required
Response: Each Fund has adopted an 80% investment policy referencing its index.
2. Please confirm supplementally whether footnote 1 to each Fund’s fee table discusses a unitary fee or a fee waiver. Please provide supplementally the document memorializing the arrangement.
Response: The Registrant notes that the footnote reflects a unitary fee arrangement. The Funds’ investment advisory agreement memorializing the unitary fee will be provided under separate cover.
3. We note that each Fund’s principal investment strategies discuss the establishment of new options positions on a daily basis, while also disclosing that the Fund may invest in options positions that expire in a week or less. Please reconcile the disclosures.
Response: The Amendment has been revised to clarify that the Funds expect to invest primarily in options contracts with daily expiry, while they also have the ability to invest in longer dated options contracts, as market conditions dictate.
* * *
Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.
February 14, 2025
Page 2
We hope that the foregoing has been responsive to your comments. If you have any questions or concerns about the responses set forth above, please call the undersigned at (202) 220-8412.
Sincerely,
/s/ Eric Simanek
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Eversheds Sutherland (US) LLP
700 Sixth Street, NW, Suite 700
Washington, DC 20001-3980
D: +1 202.220.8412
F: +1 202.637.3593
ericsimanek@
eversheds-sutherland.com
February 14, 2025
Via EDGAR
Valerie Lithotomos
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: Strategic Trust
File Nos.: 333-258490,
811-27323
Dear Ms. Lithotomos:
On behalf of Strategic Trust (the “Trust”
or the “Registrant”) and its series, Daily Delta N100 Downside Option Strategy ETF, Daily Delta N100 Upside Option Strategy
ETF, Daily Delta R2000 Downside Option Strategy ETF, Daily Delta R2000 Upside Option Strategy ETF, Daily Delta S500 Downside Option Strategy
ETF and Daily Delta S500 Upside Option Strategy ETF (each and “Fund” and, together, the “Funds”), set forth below
are the Registrant’s responses to the comments provided by the staff of the Division of Investment Management (the “Staff”)
of the Securities and Exchange Commission (the “SEC”) on February 13, 2025 regarding the Registrant’s Post-Effective
Amendment No. 25 to the Registrant’s registration statement on Form N-1A (the “Amendment”). The Staff’s comments
are set forth below and are followed by the Company’s responses.
1. With respect to each Fund, please adopt an 80% investment policy referencing the Fund’s respective
index or explain why such a policy is not required
Response: Each Fund has adopted
an 80% investment policy referencing its index.
2. Please confirm supplementally whether footnote 1 to each Fund’s fee table discusses a unitary
fee or a fee waiver. Please provide supplementally the document memorializing the arrangement.
Response: The Registrant notes
that the footnote reflects a unitary fee arrangement. The Funds’ investment advisory agreement memorializing the unitary fee will
be provided under separate cover.
3. We note that each Fund’s principal investment strategies discuss the establishment of new options
positions on a daily basis, while also disclosing that the Fund may invest in options positions that expire in a week or less. Please
reconcile the disclosures.
Response: The Amendment has
been revised to clarify that the Funds expect to invest primarily in options contracts with daily expiry, while they also have the ability
to invest in longer dated options contracts, as market conditions dictate.
* * *
Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.
February 14, 2025
Page 2
We hope that the foregoing has been responsive
to your comments. If you have any questions or concerns about the responses set forth above, please call the undersigned at (202) 220-8412.
Sincerely,
/s/ Eric Simanek
Eric Simanek