Correspondence 0000894189-23-008926 from Advisor Managed Portfolios (CIK 0001970751)
Advisor Managed Portfolios (CIK 0001970751)
Date: Dec. 13, 2023 · CIK: 0001970751 · Accession: 0000894189-23-008926
AI Filing Summary & Sentiment
File numbers found in text: 333-270997, 811-23859
Letter
VIA EDGAR TRANSMISSION Division of Investment Management Washington, DC 20549 Re: Advisor Managed Portfolios (the “Trust”) File No: 333-270997; 811-23859 Zevenbergen Growth Fund and Zevenbergen Genea Fund
Dear Ms. Quarles:
This correspondence is being filed in response to comments provided by the staff of the U.S. Securities and Exchange Commission on December 8, 2023, with respect to Post-Effective Amendment No. 3 to the Trust’s registration statement, which was filed on August 18, 2023 to add two new series to the Trust: Zevenbergen Growth Fund and Zevenbergen Genea Fund (together, the “Funds”). The Funds are being registered in order to serve as the surviving funds in “shell reorganizations” with series of another registered investment company, and will not commence a public offering until the completion of the reorganizations. The reorganizations are expected to occur on or about January 19, 2024.
For your convenience, the comments have been reproduced below in bold typeface immediately followed by the Trust’s responses. Where comments relate to or involve language that is repeated or restated in the registration statement, the Trust will make corresponding and consistent changes as appropriate throughout the registration statement.
Statement of Additional Information
Comment 1. Please revise the second sentence under the narrative disclosure related to fundamental investment policy (7) to remove the reference to the “staff,” so the sentence reads “The SEC has stated...constitutes concentration.”
Response: The Trust responds by making the requested revision.
Comment 2. Please revise the disclosure related to fundamental investment policy (7) so that each reference to “industry” also includes an appropriate reference to a “group of industries” in alignment with fundamental policy (7).
Response: The Trust responds by making the requested revisions.
Comment 3. Please include the control persons and principal holders information for the Predecessor Funds as of a specific date no more than 30 days prior to the filing date of the amended registration statement.
Response: The Trust responds by making the requested revision.
If you have any questions or comments concerning this filing, please feel free to contact Rachel Spearo (414-516-1692) or Scott Resnick (626-914-7372) of U.S. Bank Global Fund Services, the Trust’s administrator.
Sincerely,
/s/ Russell Simon
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CORRESP 1 filename1.htm Document Advisor Managed Portfolios c/o U.S. Bancorp Fund Services, LLC 615 East Michigan Street Milwaukee, Wisconsin 53202 VIA EDGAR TRANSMISSION December 13, 2023 Ms. Ellie Quarles U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Advisor Managed Portfolios (the “Trust”) File No: 333-270997; 811-23859 Zevenbergen Growth Fund and Zevenbergen Genea Fund Dear Ms. Quarles: This correspondence is being filed in response to comments provided by the staff of the U.S. Securities and Exchange Commission on December 8, 2023, with respect to Post-Effective Amendment No. 3 to the Trust’s registration statement, which was filed on August 18, 2023 to add two new series to the Trust: Zevenbergen Growth Fund and Zevenbergen Genea Fund (together, the “Funds”). The Funds are being registered in order to serve as the surviving funds in “shell reorganizations” with series of another registered investment company, and will not commence a public offering until the completion of the reorganizations. The reorganizations are expected to occur on or about January 19, 2024. For your convenience, the comments have been reproduced below in bold typeface immediately followed by the Trust’s responses. Where comments relate to or involve language that is repeated or restated in the registration statement, the Trust will make corresponding and consistent changes as appropriate throughout the registration statement. Statement of Additional Information Comment 1. Please revise the second sentence under the narrative disclosure related to fundamental investment policy (7) to remove the reference to the “staff,” so the sentence reads “The SEC has stated...constitutes concentration.” Response: The Trust responds by making the requested revision. Comment 2. Please revise the disclosure related to fundamental investment policy (7) so that each reference to “industry” also includes an appropriate reference to a “group of industries” in alignment with fundamental policy (7). Response: The Trust responds by making the requested revisions. Comment 3. Please include the control persons and principal holders information for the Predecessor Funds as of a specific date no more than 30 days prior to the filing date of the amended registration statement. Response: The Trust responds by making the requested revision. If you have any questions or comments concerning this filing, please feel free to contact Rachel Spearo (414-516-1692) or Scott Resnick (626-914-7372) of U.S. Bank Global Fund Services, the Trust’s administrator. Sincerely, /s/ Russell Simon Russell Simon President Advisor Managed Portfolios 1