Correspondence 0001580642-24-002876 from CANTOR SELECT PORTFOLIOS TRUST (CIK 0001903606)
CANTOR SELECT PORTFOLIOS TRUST (CIK 0001903606)
Date: May 29, 2024 · CIK: 0001903606 · Accession: 0001580642-24-002876
AI Filing Summary & Sentiment
File numbers found in text: 333-278771
Letter
F 404.682.7863 May 29, 2024 VIA EDGAR ========== Lauren Hamilton Division of Investment Management Securities and Exchange Commission Filing Desk 100 F Street, N.E. Washington, DC 20549 RE: Cantor Select Portfolios Trust; File No. 333-278771
Dear Ms. Hamilton,
On April 17, 2024, Cantor Select Portfolios Trust (the “Trust” or the “Registrant”) filed a combined proxy statement and registration statement under the Securities Act of 1933 on Form N-14 (the “Registration Statement”) in connection with the reorganization of each of the Aquila High Income Fund and the Aquila Opportunity Growth Fund, each a series of the Aquila Funds Trust (the “Existing Funds”) into each of the Cantor Fitzgerald High Income Fund and the Cantor Fitzgerald Equity Opportunity Fund, respectively (the “New Funds”), each a series of the Trust, in exchange for shares of the New Funds and the assumption by the New Funds of the liabilities of the Existing Funds. On May 7, 2024, you provided oral accounting comments to the Registration Statement. On May 14, 2024, Ashley Vroman-Lee provided oral comments to the Registration Statement. On May 22, 2024, we filed a pre-effective amendment to the Registration Statement addressing both sets of comments. On May 29, 2024, you provided an oral accounting comment to the pre-effective amendment to the Registration Statement. Please find below a summary of that comment and the Registrant's response, which the Registrant has authorized us to make on behalf of the Registrant.
N-14 Prospectus for Aquila High Income Fund/Cantor Fitzgerald High Income Fund:
Comment. In the capitalization table, the NAVs presented for the Existing Fund appear to be the same as of 3/31/24 as they were as of 12/31/23. Please confirm the information presented is accurate. If inaccurate, please revise the table accordingly. If accurate, please provide an explanation as to why the NAVs did not change over that period.
Response. The Existing Fund has confirmed to the Registrant that the NAVs presented in the capitalization table are accurate and that they are the same as of 3/31/24 as they were as of 12/31/23. The Existing Fund noted that net assets of the Existing Fund decreased by approximately $5.8 million between 12/31/23 and 3/28/24, and the shares outstanding for each class also decreased during that time period; however, notwithstanding such changes in net assets and shares outstanding, the calculation of the net asset value per share of each class of shares of the Existing Fund resulted in the same net asset value per share for each class on 12/31/23 and 3/31/24.
* * *
If you have any questions or comments, please contact the undersigned at 404.736.7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
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DLA Piper LLP (US)
One Atlantic Center
1201 West Peachtree Street
Suite 2900
Atlanta, Georgia 30309-3449
www.dlapiper.com
Tanya L. Boyle
tanya.boyle@us.dlapiper.com
T 404.736.7863
F 404.682.7863
May 29, 2024
VIA EDGAR
==========
Lauren Hamilton
Division of Investment Management
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549
RE: Cantor Select Portfolios Trust; File No. 333-278771
Dear Ms. Hamilton,
On April 17, 2024, Cantor Select Portfolios
Trust (the “Trust” or the “Registrant”) filed a combined proxy statement and registration statement under the
Securities Act of 1933 on Form N-14 (the “Registration Statement”) in connection with the reorganization of each of the Aquila
High Income Fund and the Aquila Opportunity Growth Fund, each a series of the Aquila Funds Trust (the “Existing Funds”) into
each of the Cantor Fitzgerald High Income Fund and the Cantor Fitzgerald Equity Opportunity Fund, respectively (the “New Funds”),
each a series of the Trust, in exchange for shares of the New Funds and the assumption by the New Funds of the liabilities of the Existing
Funds. On May 7, 2024, you provided oral accounting comments to the Registration Statement. On May 14, 2024, Ashley Vroman-Lee provided
oral comments to the Registration Statement. On May 22, 2024, we filed a pre-effective amendment to the Registration Statement addressing
both sets of comments. On May 29, 2024, you provided an oral accounting comment to the pre-effective amendment to the Registration Statement.
Please find below a summary of that comment and the Registrant's response, which the Registrant has authorized us to make on behalf of
the Registrant.
N-14 Prospectus for Aquila High Income
Fund/Cantor Fitzgerald High Income Fund:
Comment. In the capitalization table,
the NAVs presented for the Existing Fund appear to be the same as of 3/31/24 as they were as of 12/31/23. Please confirm the information
presented is accurate. If inaccurate, please revise the table accordingly. If accurate, please provide an explanation as to why the NAVs
did not change over that period.
Response. The Existing Fund has confirmed
to the Registrant that the NAVs presented in the capitalization table are accurate and that they are the same as of 3/31/24 as they were
as of 12/31/23. The Existing Fund noted that net assets of the Existing Fund decreased by approximately $5.8 million between 12/31/23
and 3/28/24, and the shares outstanding for each class also decreased during that time period; however, notwithstanding such changes in
net assets and shares outstanding, the calculation of the net asset value per share of each class of shares of the Existing Fund resulted
in the same net asset value per share for each class on 12/31/23 and 3/31/24.
* * *
If you have any questions or comments, please
contact the undersigned at 404.736.7863. Thank you in advance for your consideration.
Sincerely,
/s/ Tanya L. Boyle
Tanya L. Boyle