Correspondence 0002061590-25-000069 from Grayscale Funds Trust (CIK 0001976672)
Grayscale Funds Trust (CIK 0001976672)
Date: May 13, 2025 · CIK: 0001976672 · Accession: 0002061590-25-000069
AI Filing Summary & Sentiment
File numbers found in text: 333-271770, 811-23876
Letter
Washington, DC 20549 Subject: Grayscale Funds Trust (the “Registrant” or “Trust”) (File Nos. 333-271770; 811-23876)
Dear Mr. Worthington:
On behalf of the Registrant, below are the Registrant’s responses to the comments you provided to Susan Lively of Grayscale Advisors, LLC on April 29, 2025 with regard to Post-Effective Amendment No. 22 to the Registrant’s registration statement on Form N-1A (the “Registration Statement”), filed with the U.S. Securities and Exchange Commission (“SEC”) on March 11, 2025 under the Investment Company Act of 1940, as amended (the “1940 Act”), and the Securities Act of 1933, as amended (the “Securities Act”). The Registration Statement relates to the registration of the Grayscale Artificial Intelligence Infrastructure ETF (the “Fund”). Below we have provided your comments and the Registrant’s response to each comment. Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration Statement.
1. Comment: With respect to the section of the Fund’s Prospectus titled “Principal Investment Strategy”, please include a statement to effect that the Index relies upon a rules-based
methodology.
Response: The Registrant has updated the language in the Prospectus to note that the Index is based on a rules-based methodology.
2. Comment: With respect to the section of the Fund’s Prospectus titled “Principal Investment Strategy” please explain how the Index selects leading players in each of the six
segments. Please describe what metric is used and clarify how selection is made amongst the six categories.
Response: The Registrant has updated the language in the Prospectus to explain the identification process deployed by the Index in an effort to select the leading players in each of the six segments.
* * * * *
Please do not hesitate to contact me at the above-referenced telephone number if you have any questions or wish to discuss any of the above responses presented above.
Very truly yours,
/s/ Craig Salm
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CORRESP
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filename1.htm
Grayscale Advisors, LLC
290 Harbor Drive, 4th Floor
Stamford, CT 06902
Craig Salm
+1-212-668-6674
Craig@grayscale.com
May 13, 2025
Filed via EDGAR
Mr. Timothy A. Worthington
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Subject:
Grayscale Funds Trust (the “Registrant” or “Trust”)
(File Nos. 333-271770; 811-23876)
Dear Mr. Worthington:
On behalf of the Registrant, below are the Registrant’s responses to the comments you provided to Susan Lively of Grayscale Advisors, LLC on April 29, 2025 with regard to
Post-Effective Amendment No. 22 to the Registrant’s registration statement on Form N-1A (the “Registration Statement”), filed with the U.S. Securities and Exchange Commission (“SEC”) on March 11, 2025 under the Investment Company Act of 1940, as
amended (the “1940 Act”), and the Securities Act of 1933, as amended (the “Securities Act”). The Registration Statement relates to the registration of the Grayscale Artificial Intelligence Infrastructure ETF (the “Fund”). Below we have provided your
comments and the Registrant’s response to each comment. Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration Statement.
1. Comment: With respect to the section of the Fund’s Prospectus titled “Principal Investment Strategy”, please include a statement to
effect that the Index relies upon a rules-based
methodology.
Response: The Registrant has updated the language in the Prospectus to note that the Index is based on a rules-based methodology.
2. Comment: With respect to the section of the Fund’s Prospectus titled “Principal Investment Strategy” please explain how the
Index selects leading players in each of the six
segments. Please describe what metric is used and clarify how selection is made amongst the six categories.
Response: The Registrant has updated the language in the Prospectus to explain the identification process
deployed by the Index in an effort to select the leading players in each of the six segments.
* * * * *
Please do not hesitate to contact me at the above-referenced telephone number if you have any questions or wish to discuss any of the above responses presented above.
Very truly yours,
/s/ Craig Salm
Craig Salm
Chief Legal Officer
cc: Susan Lively, Grayscale Advisors, LLC
J. Stephen Feinour, Jr., Stradley Ronon Stevens & Young, LLP
Shawn A. Hendricks, Stradley Ronon Stevens & Young, LLP