Correspondence 0001580642-24-007675 from OneAscent Capital Opportunities Fund (CIK 0002020928)
OneAscent Capital Opportunities Fund (CIK 0002020928)
Date: Dec. 18, 2024 · CIK: 0002020928 · Accession: 0001580642-24-007675
AI Filing Summary & Sentiment
File numbers found in text: 811-23957
Letter
Via EDGAR Correspondence Division of Investment Management, Disclosure Review and Accounting Office U.S. Securities & Exchange Commission SEC File No. 811-23957
Re: OneAscent Capital Opportunities Fund
Dear Mr. Szilagyi:
Thompson Hine LLP represents OneAscent Capital Opportunities Fund (formerly OneAscent Private Markets Access Fund) (the “Registrant” or “Fund”). Below are responses to your comments with respect to the Securities and Exchange Commission Staff’s review of the Registrant’s Form N-2/A filed on December 17, 2024. The Registrant has authorized us to submit these responses.
COMMENT 1. In the Statement of Assets and Liabilities, please list the par value per share.
RESPONSE: The Registrant has included the par value per share.
COMMENT 2. In the Statement of Operations, the parenthetical after Organizational costs refers to Note 3. Please confirm whether this should refer to Note 3 or Note 2.
RESPONSE: The Registrant has corrected the parenthetical to reference Note 2.
COMMENT 3. In Note 1 in the Notes to Financial Statements, the fourth paragraph states that “[t]he Fund has no operations to date other than those relating to organizational matters, including the issuance of 10,000 shares at $10.00 per share to its initial investor, the Adviser.” Please revise this disclosure so that it accurately states OneAscent Holdings, LLC, an affiliate of the Adviser, is the initial investor.
RESPONSE: The Registrant has corrected the disclosure.
COMMENT 4. Section B of Item 25 in Part C states that the financials will be filed by subsequent amendment. Please correct this to identify the financials filed with the pre-effective amendment.
RESPONSE: The Registrant has revised Section B to read as follows:
Report of Independent Registered Public Accounting Firm, Statement of Assets and Liabilities, Statement of Operations, and Notes to Financial Statements.
December 18, 2024
Page 2
Very truly yours,
/s/ Cassandra W. Borchers
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December 18, 2024
Via EDGAR Correspondence
Brian Szilagyi, CPA
Staff Accountant
Division of Investment Management, Disclosure Review and Accounting Office
U.S. Securities & Exchange Commission
Re: OneAscent Capital Opportunities Fund
SEC File No. 811-23957
Dear Mr. Szilagyi:
Thompson Hine LLP represents OneAscent Capital
Opportunities Fund (formerly OneAscent Private Markets Access Fund) (the “Registrant” or “Fund”). Below are responses
to your comments with respect to the Securities and Exchange Commission Staff’s review of the Registrant’s Form N-2/A filed
on December 17, 2024. The Registrant has authorized us to submit these responses.
COMMENT 1. In the Statement of Assets
and Liabilities, please list the par value per share.
RESPONSE: The Registrant has included the par value
per share.
COMMENT 2. In the Statement of Operations,
the parenthetical after Organizational costs refers to Note 3. Please confirm whether this should refer to Note 3 or Note 2.
RESPONSE: The Registrant has corrected the parenthetical to reference Note
2.
COMMENT 3. In Note 1 in the Notes to
Financial Statements, the fourth paragraph states that “[t]he Fund has no operations to date other than those relating to organizational
matters, including the issuance of 10,000 shares at $10.00 per share to its initial investor, the Adviser.” Please revise this disclosure
so that it accurately states OneAscent Holdings, LLC, an affiliate of the Adviser, is the initial investor.
RESPONSE: The Registrant has corrected the disclosure.
COMMENT 4. Section B of Item 25 in Part
C states that the financials will be filed by subsequent amendment. Please correct this to identify the financials filed with the pre-effective
amendment.
RESPONSE: The Registrant has revised Section B to read as follows:
Report of Independent Registered Public Accounting Firm, Statement
of Assets and Liabilities, Statement of Operations, and Notes to Financial Statements.
December 18, 2024
Page 2
Very truly yours,
/s/ Cassandra W. Borchers
Cassandra W. Borchers
cc: Martin Dean, President of the Trust
John Siverling, OneAscent Capital, LLC