Correspondence 0001580642-24-007623 from OneAscent Capital Opportunities Fund (CIK 0002020928)
OneAscent Capital Opportunities Fund (CIK 0002020928)
Date: Dec. 17, 2024 · CIK: 0002020928 · Accession: 0001580642-24-007623
AI Filing Summary & Sentiment
File numbers found in text: 811-23957
Letter
Elaine Smiley Securities and Exchange Commission SEC File No. 811-23957
Re: OneAscent Capital Opportunities Fund
Dear Ms. Smiley:
Pursuant to Rule 461 under the Securities Act of 1933, on behalf of OneAscent Capital Opportunities Fund (the "Registrant”) and ULTIMUS FUND DISTRIBUTORS, LLC, the Registrant's principal underwriter, the Registrant hereby requests acceleration of the effective date of Pre-Effective Amendment No. 4 to the Registrant's Registration Statement to December 20, 2024 or, in the alternative, acceleration to the earliest possible time after the date submitted. Absent acceleration, the Registration Statement would not become effective. The undersigned is each aware of its obligations under the 1933 Act and that the SEC may no longer require a Tandy letter to be included in this correspondence. Nonetheless, the Registrant acknowledges the following: (i) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the staff; (ii) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (iii) staff comments or changes to disclosure in response to staff comments in a filing reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and (iv) the Registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
The Amendment was filed under the Securities Act for the purpose of responding to comments from the SEC staff with respect to registration of shares of the Registrant. If you have any questions concerning this request, please contact Cassandra Borchers at (513) 352-6632.
ONEASCENT CAPITAL
OPPORTUNITIES FUND
ULTIMUS FUND DISTRIBUTORS, LLC
By: /s/ Martin Dean
By: /s/ Kevin Guerette
Print Name: Martin Dean
Print Name: Kevin Guerette
Print Title: President
Print Title: President
Show Raw Text
CORRESP 1 filename1.htm ONEASCENT CAPITAL OPPORTUNITIES FUND Ultimus Fund Distributors, LLC December 17, 2024 Via Electronic Transmission Elaine Smiley Securities and Exchange Commission Re: OneAscent Capital Opportunities Fund SEC File No. 811-23957 Dear Ms. Smiley: Pursuant to Rule 461 under the Securities Act of 1933, on behalf of OneAscent Capital Opportunities Fund (the "Registrant”) and ULTIMUS FUND DISTRIBUTORS, LLC, the Registrant's principal underwriter, the Registrant hereby requests acceleration of the effective date of Pre-Effective Amendment No. 4 to the Registrant's Registration Statement to December 20, 2024 or, in the alternative, acceleration to the earliest possible time after the date submitted. Absent acceleration, the Registration Statement would not become effective. The undersigned is each aware of its obligations under the 1933 Act and that the SEC may no longer require a Tandy letter to be included in this correspondence. Nonetheless, the Registrant acknowledges the following: (i) the Registrant is responsible for the adequacy and accuracy of the disclosure in the filings reviewed by the staff; (ii) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (iii) staff comments or changes to disclosure in response to staff comments in a filing reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and (iv) the Registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. The Amendment was filed under the Securities Act for the purpose of responding to comments from the SEC staff with respect to registration of shares of the Registrant. If you have any questions concerning this request, please contact Cassandra Borchers at (513) 352-6632. ONEASCENT CAPITAL OPPORTUNITIES FUND ULTIMUS FUND DISTRIBUTORS, LLC By: /s/ Martin Dean By: /s/ Kevin Guerette Print Name: Martin Dean Print Name: Kevin Guerette Print Title: President Print Title: President