Correspondence 0001387131-23-003420 from Volatility Shares Trust (CIK 0001884021)
Volatility Shares Trust (CIK 0001884021)
Date: March 14, 2023 · CIK: 0001884021 · Accession: 0001387131-23-003420
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File numbers found in text: 333-263619, 811-23785
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CORRESP
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Chapman
and Cutler LLP
320
South Canal Street, 27th Floor
Chicago,
Illinois 60606
T
312.845.3000
F
312.701.2361
March
15, 2023
VIA
EDGAR CORRESPONDENCE
Ashley
Vroman-Lee
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Volatility
Shares Trust
File
Nos. 333-263619; 811-23785
Dear
Ms. Vroman-Lee
This
letter responds to your comments, provided by telephone regarding the registration statements filed on Form N-1A for Volatility
Shares Trust (the “Trust”) with the Securities and Exchange Commission (the “Commission”) on December 13,
2022 (the “Registration Statements”). The Registration Statements relate to the 1x Long VIX Futures Strategy K-1 Free
ETF and -1x Short VIX Mid-Term Futures Strategy ETF (each, a “Fund” and collectively, the “Funds”),
each a series of the Trust. Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration
Statement.
Comment
1
Please
revise the Fund names to include “strategy.” Please also confirm to the staff of trhe Commission that at least 80% of the
Funds’ assets will be exposed to VIX futures.
Response
to Comment 1
The
name of each of the Funds has been revised to include “strategy” and the requested 80% test has been added to the principal
investment strategy for each Fund.
********
Please
call me at (312) 845-3484 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
Chapman and Cutler llp
By:
/s/ Morrison C. Warren
Morrison C. Warren
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