SEC Company Response from Tortoise Capital Series Trust (CIK 0002034406) — Dec 10, 2025
Tortoise Capital Series Trust (CIK 0002034406)
Date: Dec. 10, 2025 · CIK: 0002034406 · Accession: 0001213900-25-120210
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File numbers found in text: 333-281744
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CORRESP
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filename1.htm
December 10, 2025
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, D.C. 20549
Attn: Ms. Eileen Smiley
Re: Tortoise Capital Series Trust (the “Registrant”)
Post-Effective Amendment No. 20 to Registration Statement on Form N-1A
(Tortoise Nuclear Renaissance ETF)
File No. 333-281744
To the Commission:
On behalf of the Registrant, this letter is in
response to the comments provided by the staff of the U.S. Securities and Exchange Commission to Vedder Price P.C. on December 9, 2025
and December 10, 2025 with respect to Post-Effective Amendment No. 20 to the Registration Statement on Form N-1A filed on September
26, 2025 (“PEA No. 20”) for Tortoise Nuclear Renaissance ETF (the “Fund”), a series of the Registrant. Any capitalized
terms used but not defined herein have the same meanings as given to them in PEA No. 20.
1. Comment: With respect to the 80% Policy, please revise the policy to more clearly show a
meaningful nexus between portfolio companies and the focus suggested by the name.
Response:
The Registrant has revised the 80% policy as set forth in Exhibit A.
2. Comment: Please describe how the Registrant determines that a company has primary business
operations in Nuclear Industries.
Response:
The Registrant has added the following sentence to the Item 9 disclosure:
A business operation generally will be considered
a primary activity of the company if the company holds itself out as primarily engaging in that activity, has a majority of assets dedicated
to that activity or has announced a strategic focus on that activity.
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.
U.S. Securities and Exchange Commission
December 10, 2025
Page 2
Please contact the undersigned
at 312-609-7661 or deades@vedderprice.com if you have any questions.
Very truly yours,
/s/ Deborah Bielicke Eades
Deborah Bielicke Eades, Shareholder
U.S. Securities and Exchange Commission
December 10, 2025
Page 3
Exhibit A
The Fund seeks to achieve
its objective by investing in companies across the nuclear energy value chain. The Adviser believes that the global focus on decarbonization
and energy security will result in a resurgence in the growth of the nuclear energy and technology sector. The Fund seeks to invest in
companies that the Adviser believes will benefit from the resurgence in the growth of the nuclear energy and technology sector.
Under normal circumstances,
the Fund will invest at least 80% of its total assets (including assets obtained through borrowings for investment purposes) in securities
of (i) companies that the Adviser believes are expected to derive at least 50% of their revenues from activities in Nuclear Industries;
(ii) companies that have primary business operations in the business activities associated with the Nuclear Industries but that do not
currently generate net revenues; and (iii) companies with less than 50% of revenues currently derived from activities in the Nuclear Industries
but that have publicly disclosed nuclear energy as a strategic focus area and are committing significant capital expenditures (more than
20%) to activities in the Nuclear Industries. “Nuclear Industries” include (i) uranium mining and milling, (ii) reactor design
and construction, and/or (iii) operation and maintenance of nuclear reactors. The uranium mining and milling industry covers the entire
upstream fuel-supply chain from extracting uranium ore to delivering finished reactor fuel assemblies. The reactor design and construction
industry includes companies that engineer, design and build nuclear reactor technologies and intellectual property, manufacture large-scale
components for nuclear reactors (like pressure vessels and steam generators), and companies that manage end-to-end project delivery including
engineering, procurement of specialist equipment, and onsite construction. The operation and maintenance industry includes companies that
own and operate nuclear reactors day-to-day, as well as the service companies that supply spare parts, handle refueling outages, perform
inspections, and carry out upgrades and long-term maintenance.