ALPS Series Trust
1290 Broadway, Suite 1100
Denver, Colorado 80203
May 15, 2018
VIA EDGAR
Ms. Samantha Brutlag
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | ALPS Series Trust (the “Registrant”) |
File Nos. 811-22747
Schedule 14A – Definitive Proxy
Dear Ms. Brutlag:
On behalf of the Registrant, attached hereto for filing pursuant to Rule 14a-6 under the Securities Exchange Act of 1934 (the “1934 Act”) are the definitive proxy statement, form of proxy and other soliciting materials (the “Proxy Materials”) relating to a Special Meeting of Shareholders of the Insignia Macro Fund, a series of the Registrant (the “Fund”), to be held on July 6, 2018. The Registrant estimates that copies of the Proxy Materials will be released to shareholders of the Fund on or around May 15, 2018.
The Proxy Materials are being filed to update the preliminary proxy statement, form of proxy and other soliciting materials filed on May 4, 2018 (the “Preliminary Materials”), in response to oral comments received from the staff of the U.S. Securities and Exchange Commission (the “Staff” or “Commission”) on May 11, 2018. In addition, the Proxy Materials filed herewith reflect the completion of certain data points and other non-material clerical changes to the Preliminary Materials.
Set forth in the lettered paragraphs below are the Staff’s oral comments provided on May 11, 2018, accompanied by the Registrant’s responses to each comment. Capitalized terms not otherwise defined herein shall have the meanings given to them in the Proxy Materials.
Staff Comments:
A. | Staff Comment: On page 18, under “New Agreements,” at the end of the first paragraph, please add the fees associated with each agreement, or provide a cross-reference to the section of the proxy statement where such fees are disclosed. |
U.S. Securities and Exchange Commission
Division of Investment Management
May 15, 2018
Page 2
Registrant’s Response: This comment has been complied with. The follow parenthetical has been added at the end of the last sentence of the paragraph:
“(for a description of the fees, see “Description and Comparison of Prior and New Agreements – Compensation” below)”
B. | Staff Comment: Please confirm that the proxy conforms to the requirements of Schedule 14A, Item 22(c). |
Registrant’s Response: Confirmed.
* * * * *
If you have any questions or further comments, please contact Peter Schwartz, counsel to the Registrant, at (303) 892-7381.
Very truly yours, | ||
/s/ Richard C. Noyes | ||
Richard C. Noyes | ||
Secretary of ALPS Series Trust |
cc: | Peter H. Schwartz, Esq., Davis Graham & Stubbs LLP |