Correspondence 0001213900-24-077589 from Palmer Square Funds Trust (CIK 0002014487)
Palmer Square Funds Trust (CIK 0002014487)
Date: Sept. 11, 2024 · CIK: 0002014487 · Accession: 0001213900-24-077589
AI Filing Summary & Sentiment
File numbers found in text: 333-277718, 811-23946
Letter
VIA EDGAR Division of Investment Management Attn: Ms. Eileen Smiley Re: Palmer Square Funds Trust Registration Statement on Form N-1A File Nos. 333-277718 and 811-23946
Dear Ms. Smiley:
On behalf of Palmer Square Funds Trust (the “Registrant”), we are responding to the staff’s comments provided telephonically on September 11, 2024, regarding the Registrant’s Pre-Effective Amendment 3 on Form N-1A filed on September 11, 2024 (the “Registration Statement”).
For convenience, each comment is restated below, with the response immediately following. To the extent responses herein reflect revised or additional disclosure, such disclosure will be included in the Registrant’s Form 497 filing including the comments below. The Registrant confirms it will not sell shares prior to making its Form 497 filing. All capitalized terms not defined herein have the meaning assigned to them in the Registration Statement; any page references herein refer to the prospectus and Statement of Additional Information included in Pre-effective Amendment No. 3.
1. Comment: With respect to the disclosure on the exclusive jurisdiction for claims under the federal securities laws in the SAI, please add disclosure that the reason such a provision may be unenforceable is that both the Securities Act of 1933 and the Investment Company Act of 1940 permit claims under the federal securities laws to be brought in both federal and state court.
Response: Registrant has made the requested change.
2. Comment: With respect to the disclosure on the exclusive jurisdiction for claims under the federal securities laws in the SAI, please add disclosure that such a provision may require a shareholder to bring a claim in an inconvenient or less favorable forum similar to the disclosure used in describing claims required to be brought in Delaware.
Response: Registrant has made the requested change.
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.
September 11, 2024
Page 2
If you have any questions regarding these responses, please contact the undersigned at (312) 609-7661 or Joseph Mannon at 312-609-7883.
Very truly yours,
/s/ Deborah Bielicke Eades
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CORRESP
1
filename1.htm
September 11, 2024
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
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street NE
Washington, DC 20549
Attn:
Ms. Eileen Smiley
Re: Palmer Square Funds Trust
Registration Statement on Form N-1A
File Nos. 333-277718 and 811-23946
Dear Ms. Smiley:
On behalf of Palmer Square Funds Trust (the “Registrant”),
we are responding to the staff’s comments provided telephonically on September 11, 2024, regarding the Registrant’s Pre-Effective
Amendment 3 on Form N-1A filed on September 11, 2024 (the “Registration Statement”).
For convenience, each comment is restated below,
with the response immediately following. To the extent responses herein reflect revised or additional disclosure, such disclosure will
be included in the Registrant’s Form 497 filing including the comments below. The Registrant confirms it will not sell shares prior
to making its Form 497 filing. All capitalized terms not defined herein have the meaning assigned to them in the Registration Statement;
any page references herein refer to the prospectus and Statement of Additional Information included in Pre-effective Amendment No. 3.
1. Comment: With respect to the disclosure on the exclusive jurisdiction for claims under the
federal securities laws in the SAI, please add disclosure that the reason such a provision may be unenforceable is that both the Securities
Act of 1933 and the Investment Company Act of 1940 permit claims under the federal securities laws to be brought in both federal and state
court.
Response:
Registrant has made the requested change.
2. Comment: With respect to the disclosure on the exclusive jurisdiction for claims under the
federal securities laws in the SAI, please add disclosure that such a provision may require a shareholder to bring a claim in an inconvenient
or less favorable forum similar to the disclosure used in describing claims required to be brought in Delaware.
Response: Registrant
has made the requested change.
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.
September 11, 2024
Page 2
If you have any questions regarding
these responses, please contact the undersigned at (312) 609-7661 or Joseph Mannon at 312-609-7883.
Very truly yours,
/s/ Deborah Bielicke Eades
Deborah Bielicke Eades
Shareholder