Correspondence 0001999371-23-000312 from SP Funds Trust (CIK 0001989916)
SP Funds Trust (CIK 0001989916)
Date: Nov. 16, 2023 · CIK: 0001989916 · Accession: 0001999371-23-000312
AI Filing Summary & Sentiment
File numbers found in text: 333-274015, 811-23893
Letter
VIA EDGAR Re: SP Funds S&P Sharia Global Technology ETF SP Funds S&P World ETF Registration Statement on Form N-1A File Nos. 333-274015 and 811-23893
Dear Mr. Bellacicco:
On behalf of the registrant, SP Funds Trust (the “Registrant”), we are responding to the Staff’s comments in regard to the Registrant’s Pre-Effective Amendment No. 2 to the registration statement on Form N-1A (the “Registration Statement”). For convenience, the comments are restated below, with the response immediately following. In addition, this filing reflects the completion of all missing information in the Registration Statement and the fling of all remaining exhibits.
PROSPECTUS
1. Comment: Please add additional disclosure in an appropriate location in the prospectus with respect to provisions of the Declaration of Trust relating to the procedures for derivative actions including demand requirements, the 10% ownership requirement, the Board investigation time, and shareholder reimbursement obligations. Please also disclose that certain suits are required to be brought as derivative actions notwithstanding that they may give rise to an individual claim. Please disclose that the foregoing provisions do not apply to suits under the federal securities laws.
Response: Registrant has added the requested disclosure.
2. Comment: Please add disclosure in an appropriate location in the prospectus regarding the exclusive jurisdiction and waiver of jury trial provisions. Please disclose that such provisions may require shareholders to bring suit in an inconvenient or unfavorable jurisdiction. Please disclosure potential limitations on enforceability.
Response: Registrant has added the requested disclosure.
North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005
Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
November 16, 2023
Page 2
PART C
3. Comment: Please add the language required by Rule 484(b)(3) of the Securities Act of 1933 to Item 30 of Part C.
RESPONSE: Registrant has added the requested disclosure.
If you have any questions regarding these responses, please contact the undersigned at (312) 609-7661.
Very
truly yours,
/s/ Deborah Bielicke Eades
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CORRESP
1
filename1.htm
November 16, 2023
VIA EDGAR
Chicago
New York
Washington,
DC
London
San Francisco
Los Angeles
Singapore
Dallas
Miami
vedderprice.com
Deborah Bielicke Eades
Shareholder
+1 312 609 7661
deades@vedderprice.com
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street NE
Washington, DC 20549
Attn: Mr. Christopher R. Bellacicco
Re: SP Funds S&P Sharia Global Technology ETF
SP Funds S&P World ETF
Registration Statement on Form N-1A
File Nos. 333-274015 and 811-23893
Dear
Mr. Bellacicco:
On behalf of the registrant, SP Funds Trust
(the “Registrant”), we are responding to the Staff’s comments in regard to the Registrant’s Pre-Effective Amendment
No. 2 to the registration statement on Form N-1A (the “Registration Statement”). For convenience, the comments are restated
below, with the response immediately following. In addition, this filing reflects the completion of all missing information in the Registration
Statement and the fling of all remaining exhibits.
PROSPECTUS
1. Comment: Please add additional disclosure in an appropriate location in the
prospectus with respect to provisions of the Declaration of Trust relating to the procedures for derivative actions including
demand requirements, the 10% ownership requirement, the Board investigation time, and shareholder reimbursement obligations. Please
also disclose that certain suits are required to be brought as derivative actions notwithstanding that they may give rise to an
individual claim. Please disclose that the foregoing provisions do not apply to suits under the federal securities laws.
Response:
Registrant has added the requested disclosure.
2. Comment: Please add disclosure in an appropriate location in the prospectus regarding the
exclusive jurisdiction and waiver of jury trial provisions. Please disclose that such provisions may require shareholders to bring suit
in an inconvenient or unfavorable jurisdiction. Please disclosure potential limitations on enforceability.
Response:
Registrant has added the requested disclosure.
222
North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005
Vedder
Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California,
Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.
November 16, 2023
Page 2
PART C
3. Comment: Please add the language required by Rule 484(b)(3)
of the Securities Act of 1933 to Item 30 of Part C.
RESPONSE:
Registrant has added the requested disclosure.
If you have any questions regarding
these responses, please contact the undersigned at (312) 609-7661.
Very
truly yours,
/s/ Deborah Bielicke Eades
Deborah Bielicke Eades
Shareholder