Magda El Guindi-Rosenbaum
+1.202.373.6091
mer@morganlewis.com
VIA EDGAR
June 25, 2019
Rebecca Marquigny, Esq.
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: | Aspiriant Trust (File Nos. 333-178600 and 811-22648) |
Dear Ms. Marquigny:
On behalf of Aspiriant Trust (the “Trust”), this letter provides updated fee tables and expense examples as requested in connection with post-effective amendment no. 26 to the Trust’s registration statement on Form N-1A, which was filed on May 2, 2019. The fee tables and expense examples are included in the attached appendix.
Please contact me at (202) 373-6091 with questions or comments.
Sincerely,
/s/ Magda El Guindi-Rosenbaum
Magda El Guindi-Rosenbaum
cc: | Benjamin D. Schmidt, Aspiriant Trust |
Morgan, Lewis & Bockius llp
1111 Pennsylvania Avenue, NW Washington, DC 20004 United States | +1.202.739.3000 +1.202.739.3001 |
APPENDIX
Aspiriant Risk-Managed Equity Allocation Fund
Fees and Expenses
This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund.
Shareholder Fees (fees paid directly from your investment): | ||
Advisor Shares | Institutional Shares | |
Maximum Sales Charge (Load) Imposed on Purchases (as percentage of offering price) | NONE | NONE |
Maximum Deferred Sales Charge (Load) (as a percentage of net asset value) | NONE | NONE |
Maximum Sales Charge (Load) Imposed on Reinvested Dividends | NONE | NONE |
Redemption Fee (as percentage of amount redeemed) (on shares held for 90 days or less) | NONE | 2.00% |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment): | ||
Advisor Shares | Institutional Shares(1) | |
Management Fees | 0.24% | 0.24% |
Distribution (12b-1) Fees | NONE | 0.25% |
Other Expenses | 0.14% | 0.14% |
Acquired Fund Fees and Expenses(2) | 0.28% | 0.28% |
Total Annual Operating Expenses | 0.66% | 0.91% |
Fee Waiver (3) | (0.08%) | (0.08%) |
Total Annual Operating Expenses After Fee Waiver | 0.58% | 0.83% |
(1) | Estimated for current fiscal year. |
(2) | Acquired Fund Fees and Expenses represent fees and expenses incurred indirectly by the Fund as a result of its investment in other investment companies. Total Annual Operating Expenses and Total Annual Operating Expenses After Fee Waiver in this table may not correlate to the gross and net ratios of expenses to average net assets provided in the Financial Highlights section of this prospectus, which reflects the operating expenses of the Fund and does not include Acquired Fund Fees and Expenses. |
(3) | The Adviser has contractually agreed to waive its advisory fee from 0.24% to 0.16% through June 30, 2020. This arrangement may be terminated only by the Trust’s Board of Trustees. |
Example
This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
1 Year | 3 Years | 5 Years | 10 Years | |
Advisor Shares | $59 | $203 | $360 | $815 |
Institutional Shares | $85 | $282 | $496 | $1,112 |
1
Aspiriant Risk-Managed Municipal Bond Fund
Fees and Expenses
This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund.
Shareholder Fees (fees paid directly from your investment): | ||
Maximum Sales Charge (Load) Imposed on Purchases (as percentage of offering price) | NONE | |
Maximum Deferred Sales Charge (Load) (as percentage of net asset value) | NONE | |
Maximum Sales Charge (Load) Imposed on Reinvested Dividends | NONE | |
Redemption Fee (as percentage of amount redeemed) | NONE |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment): | ||
Management Fees | 0.27% | |
Distribution (12b-1) Fees | NONE | |
Other Expenses | 0.12% | |
Acquired Fund Fees and Expenses (1) | 0.18% | |
Total Annual Operating Expenses | 0.57% | |
Fee Waiver (2) | (0.06%) | |
Total Annual Operating Expenses After Fee Waiver | 0.51% |
(1) | Acquired Fund Fees and Expenses represent fees and expenses incurred indirectly by the Fund as a result of its investment in other investment companies. Total Annual Operating Expenses and Total Annual Operating Expenses After Fee Waiver in this table may not correlate to the gross and net ratios of expenses to average net assets provided in the Financial Highlights section of this prospectus, which reflects the operating expenses of the Fund and does not include Acquired Fund Fees and Expenses. |
(2) | The Adviser has contractually agreed to waive its advisory fee from 0.27% to 0.21% through June 30, 2020. This arrangement may be terminated only by the Trust’s Board of Trustees. |
Example
This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
1 Year | 3 Years | 5 Years | 10 Years |
$52 | $177 | $312 | $708 |
2
Aspiriant Defensive Allocation Fund
Fees and Expenses
This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund.
Shareholder Fees (fees paid directly from your investment): | ||
Maximum Sales Charge (Load) Imposed on Purchases (as percentage of offering price) | NONE | |
Maximum Deferred Sales Charge (Load) (as percentage of net asset value) | NONE | |
Maximum Sales Charge (Load) Imposed on Reinvested Dividends | NONE | |
Redemption Fee (as percentage of amount redeemed) | NONE |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment): | ||
Management Fees | 0.10% | |
Distribution (12b-1) Fees | NONE | |
Other Expenses | 0.09% | |
Acquired Fund Fees and Expenses(1) | 0.82% | |
Total Annual Operating Expenses | 1.01% |
(1) | Acquired Fund Fees and Expenses represent fees and expenses incurred indirectly by the Fund as a result of its investment in other investment companies. Total Annual Operating Expenses in this table may not correlate to the ratio of expenses to average net assets provided in the Financial Highlights section of this prospectus, which reflects the operating expenses of the Fund and does not include Acquired Fund Fees and Expenses. |
Example
This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
1 Year | 3 Years | 5 Years | 10 Years |
$103 | $322 | $558 | $1,236 |
3
Aspiriant Risk-Managed Taxable Bond Fund
Fees and Expenses
This table describes the fees and expenses that you may pay if you buy and hold shares of the Fund.
Shareholder Fees (fees paid directly from your investment): | ||
Maximum Sales Charge (Load) Imposed on Purchases (as percentage of offering price) | NONE | |
Maximum Deferred Sales Charge (Load) (as percentage of net asset value) | NONE | |
Maximum Sales Charge (Load) Imposed on Reinvested Dividends | NONE | |
Redemption Fee (as percentage of amount redeemed) | NONE |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment): | ||
Management Fees | 0.25% | |
Distribution (12b-1) Fees | NONE | |
Other Expenses | 0.28% | |
Acquired Fund Fees and Expenses(1) | 0.35% | |
Total Annual Operating Expenses | 0.88% | |
Fee Waiver(2) | (0.17%) | |
Total Annual Operating Expenses After Fee Waiver | 0.71% |
(1) | Acquired Fund Fees and Expenses represent fees and expenses incurred indirectly by the Fund as a result of its investment in other investment companies. |
(2) | The Adviser has contractually agreed to waive its advisory fee from 0.25% to 0.08% through June 30, 2020. This arrangement may be terminated only by the Trust’s Board of Trustees. |
Example
This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
1 Year | 3 Years | 5 Years | 10 Years |
$73 | $264 | $471 | $1,069 |
4