Correspondence 0001193125-24-223834 from Lincoln Funds Trust (CIK 0002015799)
Lincoln Funds Trust (CIK 0002015799)
Date: Sept. 23, 2024 · CIK: 0002015799 · Accession: 0001193125-24-223834
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File numbers found in text: 333-278528, 811-23952
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CORRESP 1 filename1.htm Lincoln Funds Trust VIA EDGAR September 23, 2024 Seamus O’Brien, Esq. Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-4644 RE: Registrant: Lincoln Funds Trust (the “Trust”) File Nos.: File Nos. 333-278528 and 811-23952 Funds: Lincoln Inflation Plus Fund (the “Fund”) Dear Mr. O’Brien: This letter responds to your comments, provided via phone meeting on September 11, 2024, to the Trust’s initial comment response letter (“Registrant’s Response”) regarding registration statement filed on Form N-1A on April 5, 2024, under Rule 485(a) under the Securities Act of 1933 (the “Registration Statement”). The following are your comments and the Trust’s responses. 1. Please clarify the discussion in the statement of additional information (“SAI”) under the fundamental investment policy section to explain that the Fund will consider underlying fund holdings to the extent they are known or should be known to the Fund. RESPONSE: The requested revision has been made. The Registrant has updated the Fund’s disclosure in this section as follows: For purposes of the concentration policy, each Fund will consider the portfolio holdings of any underlying funds held by the Fund. Your consideration of this filing is much appreciated. Please contact me at the number indicated above with any questions. Very truly yours, /s/ Samuel K. Goldstein Samuel K. Goldstein, Esq. Chief Counsel – Funds Management Enclosures cc: Ronald A. Holinsky, Esq. Christian Pfeiffer, Esq. Teriana Griggs 1