Correspondence 0001580642-25-001543 from CANTOR SELECT PORTFOLIOS TRUST (CIK 0001903606)
CANTOR SELECT PORTFOLIOS TRUST (CIK 0001903606)
Date: March 7, 2025 · CIK: 0001903606 · Accession: 0001580642-25-001543
AI Filing Summary & Sentiment
File numbers found in text: 333-262101, 811-23774
Letter
March 7, 2025 VIA EDGAR Lauren Hamilton Staff Accountant Securities and Exchange Commission Filing Desk 100 F Street, N.E. Washington, DC 20549
Re: Cantor Select Portfolios Trust (the “Trust”); File Nos. 333-262101 and 811-23774
Dear Ms. Hamilton:
On February 5, 2025, you provided comments by telephone to Tanya Boyle to the annual report and related filings for the period ended September 30, 2024 of the Cantor Fitzgerald Equity Dividend Plus Fund, Cantor Fitzgerald Large Cap Focused Fund, and Cantor Fitzgerald International Equity Fund, each a series of the Trust (the “Funds”). Please find below a summary of those comments and the Trust's responses, which the Trust has authorized DLA Piper LLP to make on behalf of the Trust.
Comment 1. In the N-PORT filing for each series for the period ended September 30, 2024, the Staff notes that the information provided in Item B.5 contains returns that differ greatly from class to class within a fund each month (high variance between classes in same fund). Please supplementally confirm that the information presented reflects accurate return information by class for each monthly period. If the return information is not accurate, please amend the filings to correct the information presented.
Response. The fund accountant has confirmed to the Trust that the information presented for each Fund is accurate as reported.
Comment 2. The Staff notes that an amended N-CEN was filed on 12/13/24. Please supplementally explain the reason for the amended filing.
Response. The box indicating that the N-CEN was being filed for all series was inadvertently selected on the original filing, which included two series that have different fiscal year ends than the Funds and should not have been included in the filing. The amended N-CEN was filed to limit the filing to the three series for which it was being filed.
Comment 3. On the N-CEN, the Cantor Fitzgerald International Equity Fund indicated that it hired an adviser and sub-adviser during the period. Please confirm a shareholder vote was obtained in accordance with section 15.
Response. The vote of the initial shareholder was obtained in accordance with Section 15 of the 1940 Act. The hiring of the adviser and sub-adviser referenced in the filing was the initial hiring of the respective advisers.
March 7, 2025
Page Two
Comment 4. In the annual financial statements, the Staff notes that 8.5% of the Cantor Fitzgerald Equity Dividend Plus Fund was invested in the Fidelity Government Portfolio. Please supplementally confirm that the one basis point of acquired fund fees and expenses shown in the 2/1/25 prospectus was calculated in accordance with the requirements of Form N-1A.
Response. The fund accountant has confirmed to the Fund that the AFFE was calculated in accordance with the requirements of Form N-1A.
Comment 5. In the TSR for the Class A shares of the Cantor Fitzgerald International Equity Fund, the line graph presented for Class A does not disclose that the information shown is presented with a sales load the way it does for the other funds. Please supplementally confirm that the fund will comply with the requirements of Item 27(a), subsection d.2, instruction 2 of Form N-1A going forward. conform with N-1A requirements going forward.
Response. The Fund will comply with the N-1A requirements going forward.
Comment 6. The Staff notes that the disclosure regarding open options contracts written does not include all the information required by Regulation S-X 12-13, column A-G, as the counterparty was not included.
Response. The Fund will provide the required disclosure going forward.
Comment 7. The disclosure in Item 10 and Item 11 of Form N-CSR indicates that the required information is included in Item 7 of Form N-CSR. Please explain supplementally how this cross reference complies with the requirements of Item 10 and Item 11 and the SEC’s FAQ #3 on the TSR.
Response. The Trust will include the disclosure required by Item 10 and Item 11 with those items going forward instead of cross referencing the disclosure.
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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filename1.htm
March 7, 2025
VIA EDGAR
Lauren Hamilton
Staff Accountant
Securities and Exchange Commission
Filing Desk
100 F Street, N.E.
Washington, DC 20549
Re: Cantor Select Portfolios Trust (the “Trust”); File
Nos. 333-262101 and 811-23774
Dear Ms. Hamilton:
On February 5, 2025, you provided comments by
telephone to Tanya Boyle to the annual report and related filings for the period ended September 30, 2024 of the Cantor Fitzgerald
Equity Dividend Plus Fund, Cantor Fitzgerald Large Cap Focused Fund, and Cantor Fitzgerald International Equity Fund, each a series of
the Trust (the “Funds”). Please find below a summary of those comments and the Trust's responses, which the Trust has authorized
DLA Piper LLP to make on behalf of the Trust.
Comment 1. In the N-PORT filing for each
series for the period ended September 30, 2024, the Staff notes that the information provided in Item B.5 contains returns that differ
greatly from class to class within a fund each month (high variance between classes in same fund). Please supplementally confirm that
the information presented reflects accurate return information by class for each monthly period. If the return information is not accurate,
please amend the filings to correct the information presented.
Response. The fund accountant has confirmed
to the Trust that the information presented for each Fund is accurate as reported.
Comment 2. The Staff notes that an amended
N-CEN was filed on 12/13/24. Please supplementally explain the reason for the amended filing.
Response. The box indicating that the
N-CEN was being filed for all series was inadvertently selected on the original filing, which included two series that have different
fiscal year ends than the Funds and should not have been included in the filing. The amended N-CEN was filed to limit the filing to the
three series for which it was being filed.
Comment 3. On the N-CEN, the Cantor Fitzgerald
International Equity Fund indicated that it hired an adviser and sub-adviser during the period. Please confirm a shareholder vote was
obtained in accordance with section 15.
Response. The vote of the initial shareholder
was obtained in accordance with Section 15 of the 1940 Act. The hiring of the adviser and sub-adviser referenced in the filing was the
initial hiring of the respective advisers.
March 7, 2025
Page Two
Comment 4. In the annual financial statements,
the Staff notes that 8.5% of the Cantor Fitzgerald Equity Dividend Plus Fund was invested in the Fidelity Government Portfolio. Please
supplementally confirm that the one basis point of acquired fund fees and expenses shown in the 2/1/25 prospectus was calculated in accordance
with the requirements of Form N-1A.
Response. The fund accountant has confirmed
to the Fund that the AFFE was calculated in accordance with the requirements of Form N-1A.
Comment 5. In the TSR for the Class A
shares of the Cantor Fitzgerald International Equity Fund, the line graph presented for Class A does not disclose that the information
shown is presented with a sales load the way it does for the other funds. Please supplementally confirm that the fund will comply with
the requirements of Item 27(a), subsection d.2, instruction 2 of Form N-1A going forward. conform with N-1A requirements going forward.
Response. The Fund will comply with the
N-1A requirements going forward.
Comment 6. The Staff notes that the disclosure
regarding open options contracts written does not include all the information required by Regulation S-X 12-13, column A-G, as the counterparty
was not included.
Response. The Fund will provide the required
disclosure going forward.
Comment 7. The disclosure in Item 10
and Item 11 of Form N-CSR indicates that the required information is included in Item 7 of Form N-CSR. Please explain supplementally how
this cross reference complies with the requirements of Item 10 and Item 11 and the SEC’s FAQ #3 on the TSR.
Response. The Trust will include the
disclosure required by Item 10 and Item 11 with those items going forward instead of cross referencing the disclosure.
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