SEC Company Response from Elevation Series Trust (CIK 0001936157) — Apr 15, 2026
Elevation Series Trust (CIK 0001936157)
Date: April 15, 2026 · CIK: 0001936157 · Accession: 0001999371-26-008326
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File numbers found in text: 333-265972
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April 15, 2026
VIA EDGAR TRANSMISSION
Elizabeth Goody
Securities and Exchange Commission
Division of Investment
Management
100 F Street, N.E.
Washington, D.C. 20549-0506
Re: Elevation
Series Trust, File Nos. 333-265972 and 811- 23812 (“Registrant”)
Dear Ms. Goody:
On January 16, 2026, the Registrant,
on behalf of its series, CresAlta Global Dividend ETF and CresAlta Small and Mid-Cap ETF (each a “Fund”), filed an amendment
to its registration statement under the Securities Act of 1933 on Form N-1A (the “Amendment”). In a telephone conversation
on March 16, 2026, you provided comments to the Amendment. Below, please find those comments and the Registrant’s responses, which
the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added language is in italics and deleted
language appears struck through, if any.
Prospectus
CresAlta Global Dividend ETF
Principal Investment Strategies of the Fund
Comment 1: In light of
the second paragraph of this section of the Prospectus, please consider revising in order to provide additional detail regarding specific
metrics, criteria or analyses performed at each stage of the investment process and disclose any material risks associated with the investment
process, so that investors can understand how decisions are made.
Response: The Registrant has
added the following disclosures to this section:
The Adviser’s stock
selection process combines macroeconomic analysis, quantitative stock ranking, and traditional company fundamental analysis. The process
is not an automated model. Buying and selling decisions are at the portfolio manager’s discretion based on review of the research.
1. The Adviser’s macroeconomic analysis divides business cycles into four phases— trough, early recovery, expansion, and peak—using
a combination of
Daniel.Filstrup@ThompsonHine.com Direct:
312.998.4248
Elizabeth
Goody
April 15, 2026
Page
2
factors, such as Purchasing
Managers Index data (PMI) and inflation, to estimate the current phase and direction of the business cycle. This macro business phase
analysis informs the quantitative stock ranking and traditional fundamental analysis by helping to determine which segment of the stock
market will benefit most from the current phase and direction of the business cycle.
2. The quantitative stock ranking is based on an analysis of factors in three distinct “factor families”: price momentum,
valuation, and business fundamentals. Stocks are ranked based on a combination of factor families that is appropriate for the current
phase and direction of the business cycle.
3. The Adviser’s traditional company analysis includes an assessment of financial statements and financial history; corporate
strategy and business outlook; competitive landscape; macroeconomic backdrop; and management effectiveness. The Adviser uses a value-investing
framework centered around dividends to classify stocks via traditional fundamental analysis to build portfolios. The Adviser’s classification
system identifies stocks as dividend value, dividend growth, or dividend payor. Portfolios are often heavily allocated to dividend growth,
which the Adviser defines as higher quality companies—usually with lower balance sheet leverage, strong free cash flows, clear capital
allocation plans, defensible businesses, an ability to grow dividends and share buybacks at an above market pace. Dividend value and dividend
payor stocks provide diversification during appropriate business cycle phases.
In addition, the Registrant has made
the following edit to avoid duplicative disclosures:
Additionally, the Adviser
utilizes a macroeconomic overlay to determine the business cycle phase of countries while rotating portfolio positions across stocks categorized
with the Adviser’s dividend category methodology. Stocks are categorized into one of three dividend categories — dividend
value, dividend growth, and dividend payer. The bulk of the portfolio is expected to consist of dividend growth stocks. The Adviser
seeks to obtain for the Fund substantial returns from such stocks via growing dividends and share buybacks. The portfolio may tilt toward
dividend value or dividend payer stocks depending on the business cycle phase.
With respect to material risks
arising from the Fund’s investment process, the Registrant believes that the risk disclosures provided in the section titled “Principal
Risks of Investing in the Fund” are comprehensive and address all material risks associated with the Fund’s investment process.
Elizabeth
Goody
April 15, 2026
Page
3
Comment 2: To the extent
that geographic concentration is a principal investment risk due to the limitation that the Fund is limited to U.S. company stocks, then
please consider including a corresponding disclosure under the section titled “Principal Investment Strategies of the Fund.”
Response: The Registrant
amended the disclosures in this section to clarify that investing in U.S. company stocks is a principal investment strategy as follows:
The Adviser begins by reviewing
a universe of more than 2,500 companies using proprietary screening methods to identify companies primarily listed on an exchange in
the U.S. that the Adviser believes are financially strong and well-managed companies that the Adviser believes are selling at attractive
valuations.
If you have any questions, please
call the undersigned at (312) 998-4248.
Very
truly yours,
/s/ Daniel Filstrup
Daniel Filstrup
cc: JoAnn M. Strasser