Internal control over financial reporting

3. Refer to your September 29, 2025 response. You say, “We have evaluated the total possible exposure related to this control deficiency and believe the maximum exposure related to the above-mentioned control deficiency is the amounts listed in the noted errors.” Since you misinterpreted the interpretive guidance, please explain in detail how the potential magnitude of the errors that could have resulted from the control deficiency would be limited to the amounts of the actual errors. For example, suppose you had additional transactions of a similar nature during each of the prior periods when the errors occurred, please explain why you believe you would have accounted for those correctly. Otherwise, please revise your response to tell us how big the errors could have been before you identified them. Also, tell us about any compensating controls and whether they were operating at a…

Comment 2 : Please confirm whether the Internal Control Report ( i.e. , the Auditor Report) included in the December 31, 2024 Form N-CEN for the FS Multi-Strategy Alternatives Fund should make reference to financial statements being consolidated [ i.e. , the financial statements for both (i) the FS Multi-Strategy Alternatives Fund and (ii) the FS Alternatives Fund (Cayman), the FS Multi-Strategy Alternatives Fund’s wholly-owned subsidiary. If these FS Multi-Strategy Alternatives Fund financial statements do represent the consolidated financial statements for both the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman), then please also confirm that, going forward, an appropriate note shall be provided in the Internal Control Report to be included in the FS Multi-Strategy Alternatives Fund’s Form N-CEN that discloses that these financial statements represent the…

4. We note you disclose that you have made and will continue to make, changes to your internal controls and procedures for financial reporting and accounting systems to meet your reporting obligations as a publicly traded company. We also note that you did not timely file a Form 10-Q for the quarter ended March 31, 2024. Please update and revise your disclosure to state that you did not timely file this Form 10-Q and that you may not be able to file timely in the future. Company

1. Please amend your filing to provide management’s report on internal control over financial reporting pursuant to Item 308 of Regulation S-K.

4. Please tell us why the certifications filed as Exhibits 31.1 and 31.2 do not include paragraph 4(b) and the introductory language in paragraph 4 referring to internal control over financial reporting. Refer to Item 601(b)(31) of Regulation S-K.

Comment 1: Please revise to disclose management’s conclusion on the effectiveness of your internal controls over financial reporting. Refer to Item 308(a)(3) of Regulation S-K.

4. Please revise to disclose the conclusion of your principal executive officer and principal financial officer as to the effectiveness of disclosure controls and procedures based upon the full definition contained in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934. In this regard, your disclosure states that your disclosure controls and procedures were effective to provide reasonable assurance that information required to be disclosed in the Company ’ s periodic filings under the Exchange Act is accumulated and communicated to your management to allow timely decisions regarding required disclosure. Tell us and revise to disclose whether your assessment also included whether your controls and other procedures were designed to ensure that information required to be disclosed in your reports is recorded, processed, summarized and reported timely. Also revise your…

5. Please also identify the version of the COSO Framework (i.e., the 2013 framework) you used in your evaluation of the Company ’ s internal control over financial reporting. Refer to Item 308(a)(2) of Regulation S-K.

3. We note the certifications provided in Exhibits 31.1 and 31.2 do not include paragraph 4(b) and the introductory language in paragraph 4 referring to internal control over financial reporting after the end of the transition period that allows these omissions. Please provide corrected certifications in an amended filing that also contains full Item 9A disclosure as well as your financial statements. Amend your Form 10-Q for the period ended March 31, 2024 in a similar manner. Refer to the guidance of Regulation S-K Compliance and Disclosure Interpretations Question 246.13. Phathom’s

9. You disclose that in January 2024, in connection with a routine tax examination of the Company’s income tax returns, the Japanese tax authority discovered misappropriations of Company funds by a former director. Please clarify for us how you were able to measure the impact of the misappropriations on your reported revenue and advances from customers’ accounts. Specifically, it is not clear why your restated 2022 net income decreased by $1.1 million and advances from customers increased by $4.2 million. In light of the related party disclosure on page 232, please disclose whether the "former director" is a relative of the CEO. Regarding the corresponding risk factor disclosure on page 84, please tell us why your system of internal controls failed to detect this misappropriation of funds and whether you are implementing any responsive changes in your system of internal controls.…

1. Please amend your filing to provide management’s annual report on internal control over financial reporting. Ensure you include a statement of management’s responsibility for establishing and maintaining adequate internal control over financial reporting and a statement identifying the framework used by management to evaluate the effectiveness of internal control over financial reporting. Also, include management’s assessment of the effectiveness of internal control over financial reporting as of December 31, 2023, including a statement as to whether or not internal control over financial reporting is effective. Refer to Item 308(a) of Regulation S-K.

2. In light of the missing internal control over financial reporting disclosures, please re-evaluate your conclusion regarding the effectiveness of disclosure controls and procedures. Also address this comment for your March 31, 2024 Form 10-Q’s conclusion for your disclosure controls and procedures.

30. Comment : Form N-CEN. The Internal Control Letters are dated months after the audit opinion for fiscal years 2020 and 2021. Please describe how the audit firms can issue a report on internal control after the audit period.

31. Comment : Form N-CEN. A. Item B 8. That section only lists two directors but the N-CSR lists four. B. Item B 8 lists the file # of this registrant. But the form asks for the File # of other registrants that the person serves as director. C. Item B 18. B18 indicates no material weakness. But the Internal Control Letter note a material weakness.

Comment : The Staff notes that the Form N-CEN B-22 for Old Westbury Credit Income Fund indicates that the Fund had a NAV error during the fiscal year ended October 31, 2022. However, there was no disclosure in the financial statements on the error, associated internal control implications, mitigating steps, or reimbursement. If the amounts related to the NAV error have been reimbursed, please explain and cite the applicable GAAP, Regulation S-X, or other relevant accounting guidance on why the Fund did not disclose these reimbursement amounts in its financial statements.

3. Refer to the second paragraph and your conclusion that disclosure controls and procedures ("DCP") were effective. However, we note that your assessment of internal control over financial reporting ("ICFR") was not effective due to the material weaknesses described therein. To the extent that ICFR has been determined to be not effective due to the material weakness identified, we would expect your DCP also to be not effective due to the substantial overlap of controls. Refer to SEC Release No. 33-8238, Section II.D. Please revise to ensure consistent conclusions for both DCP and ICFR are presented. ALR

4. In the paragraphs where you refer to management, please expand to disclose if your management includes the participation of your chief executive officer and chief financial officer. In addition, under the heading of Changes in Internal Control over Financial Reporting on page 60, please revise to disclose if there were any change in your internal control over financial reporting ("ICFR") identified in connection with your evaluation of ICFR, other than those discussed above relating to the material weakness, that occurred during your fourth fiscal quarter (i.e., quarter ended December 31, 2023) that has materially affected, or is reasonably likely to materially affect, your internal control over financial reporting. Refer to Item 308(c) of Regulation S-K and to the requirements of paragraph 4(d) of the Exhibit 12 Certifications. ALR

Comment : Item B.22 of the Fund’s Form N-CEN for the fiscal year ended December 31, 2023, indicates that the Fund had a net asset value (“NAV”) error during the reporting period. However, the Staff did not locate disclosure in the financial statements related to such error. Please describe the nature and circumstances of the error, associated internal control implications, mitigating actions and amounts reimbursed, if any. In addition, if amounts have been reimbursed, please explain, citing applicable U.S. GAAP, Regulation S-X and other accounting guidance, why the Fund has not disclosed these reimbursement amounts in its financial statements.

Comment 10 : For all the Funds, the Form N-CSR refers to a "fiscal half year" covered by the report for the disclosure related to Form N-CSR Item 11(b). Please utilize the language provided in Form N-CSR Item 11(b) which refers to period covered by the report not isolated to a particular fiscal half year and confirm that there have been no such changes in the registrant’s internal control over financial reporting that occurred during the period.

3. You disclose that your annual report does not include a report on the conclusion regarding the effectiveness of disclosure controls and procedures (“DCP”) due to a transition period established by Commission rules for newly public companies. We note that you provided DCP conclusions in each of your Forms 10-Q for the quarterly periods ended June 30, 2022, September 30, 2022 and December 31, 2022. We also note that paragraphs 4(c) of your certifications filed as Exhibits 31.1 and 31.2 indicate that you prepared the requisite evaluation of DCP and provided your conclusion in the filing. Finally, we note that Instruction 1 to Item 308 of Regulation S-K provides transition guidance for the evaluation of internal control over financial reporting but there is no similar instruction for DCP under Item 307. Please tell us whether you performed the required assessment of DCP as of March 31,…

2. The Trusts’ Form N-CEN Reports include the annual audit reports in addition to the required independent public accountant’s reports on internal control. Only the internal control reports are required to be filed.

Comment 7. The Staff notes that in the N-CSR filed for the period ending October 31, 2023, the response to Item 11(b) refers to a “quarter.” Please use language in Item 11(b) going forward that refers to the “period” of the report and does not refer to a particular quarter. Please confirm that there have been no changes in the internal controls of the Registrant’s reporting during the period.

2. Please revise the heading Evaluation of Disclosure Controls and Procedures to Management’s Report on Internal Control over Financial Reporting. In addition, you set forth that management assessed the effectiveness of our internal control over financial reporting as of July 31, 2018. Please correct the date in an amended filing. Lastly, you set forth that you used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control - Integrated Framework. Please revise your disclosure to refer to the specific framework used. Refer to Item 308 of Regulation S-K.

3. Please revise your heading to Evaluation of Disclosure Controls and Procedures to provide more clarity. In addition, you refer to December 31, 2020 two times in the paragraph, not December 31, 2023. Please correct your disclosure in an amended filing. Refer to Item 307 of Regulation S-K.

7. With respect to each AXS Fund, the Form N-CSR filing for the period September 30, 2023, discusses internal controls in Item 4d. This discussion should be for the period covered by the report. Please ensure that the internal control covers the period of the report in future filings.

5. We note that management has determined your internal control over financial reporting (ICFR) was not effective as of December 31, 2023, due to the presence of a material weakness. However, we also note management, with the participation of your Certifying Officers, concluded that disclosure controls and procedures (DCPs) were effective as of the end of the period covered by this report. Please explain to us how management was able to conclude DCPs were effective given that ICFR are an integral part of DCPs, or revise as necessary. We refer you to Sections II.D and E of SEC Release 33-8238, in which the Commission recognizes there is substantial overlap between ICFR and DCPs.

Comment 6. The disclosure included with respect to Item 11(b) of each Registrant’s Form N-CSR states that “[t]here were no changes in the Registrant’s internal control over financial reporting that occurred during the Registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report).” The Staff notes that Item 11(b) of Form N-CSR describes changes to the Registrant’s internal control over financial reporting that occurred during the “period covered by this report.” Please revise the period referred to in each Registrant’s disclosure under Item 11(b) to use the exact language provided in Form N-CSR.

Comment 7. The disclosure included with respect to 4(d) of the AIP Multi-Strategy Fund A’s Principal Executive Officer’s and Principal Financial Officer’s certifications, included as exhibits to the Form N-CSR, certify that the Principal Executive Officer and Principal Financial Officer have “disclosed in th[e] report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.” The Staff notes that Item 19(a)(3) of Form N-CSR requires the Registrant’s certifications relating to such officers’ disclosure during the “period covered by this report.” Please revise the period referred to in the Registrant’s…

Comment 6. The disclosure included with respect to Item 11(b) of each Registrant’s Form N-CSR states that “[t]here were no changes in the Registrant’s internal control over financial reporting that occurred during the Registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report).” The Staff notes that Item 11(b) of Form N-CSR describes changes to the Registrant’s internal control over financial reporting that occurred during the “period covered by this report.” Please revise the period referred to in each Registrant’s disclosure under Item 11(b) to use the exact language provided in Form N-CSR.

Comment 7. The disclosure included with respect to 4(d) of the AIP Multi-Strategy Fund A’s Principal Executive Officer’s and Principal Financial Officer’s certifications, included as exhibits to the Form N-CSR, certify that the Principal Executive Officer and Principal Financial Officer have “disclosed in th[e] report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.” The Staff notes that Item 19(a)(3) of Form N-CSR requires the Registrant’s certifications relating to such officers’ disclosure during the “period covered by this report.” Please revise the period referred to in the Registrant’s…

Comment 6. The disclosure included with respect to Item 11(b) of each Registrant’s Form N-CSR states that “[t]here were no changes in the Registrant’s internal control over financial reporting that occurred during the Registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report).” The Staff notes that Item 11(b) of Form N-CSR describes changes to the Registrant’s internal control over financial reporting that occurred during the “period covered by this report.” Please revise the period referred to in each Registrant’s disclosure under Item 11(b) to use the exact language provided in Form N-CSR.

Comment 7. The disclosure included with respect to 4(d) of the AIP Multi-Strategy Fund A’s Principal Executive Officer’s and Principal Financial Officer’s certifications, included as exhibits to the Form N-CSR, certify that the Principal Executive Officer and Principal Financial Officer have “disclosed in th[e] report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.” The Staff notes that Item 19(a)(3) of Form N-CSR requires the Registrant’s certifications relating to such officers’ disclosure during the “period covered by this report.” Please revise the period referred to in the Registrant’s…

Comment 6. The disclosure included with respect to Item 11(b) of each Registrant’s Form N-CSR states that “[t]here were no changes in the Registrant’s internal control over financial reporting that occurred during the Registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report).” The Staff notes that Item 11(b) of Form N-CSR describes changes to the Registrant’s internal control over financial reporting that occurred during the “period covered by this report.” Please revise the period referred to in each Registrant’s disclosure under Item 11(b) to use the exact language provided in Form N-CSR.

Comment 7. The disclosure included with respect to 4(d) of the AIP Multi-Strategy Fund A’s Principal Executive Officer’s and Principal Financial Officer’s certifications, included as exhibits to the Form N-CSR, certify that the Principal Executive Officer and Principal Financial Officer have “disclosed in th[e] report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.” The Staff notes that Item 19(a)(3) of Form N-CSR requires the Registrant’s certifications relating to such officers’ disclosure during the “period covered by this report.” Please revise the period referred to in the Registrant’s…

Comment : We note your disclosure that your Chief Executive Officer and Chief Financial Officer carried out an evaluation of the effectiveness of the design and operation of your disclosure controls and procedures as of December 31, 2022. Please note that your conclusions should be disclosed as of December 31, 2023, which is the end of the period covered by this report. Please amend your Form 10-K for the fiscal year ended December 31, 2023 to correct this apparent discrepancy. Refer to Item 307 of Regulation S-K.

Comment 2. Form N-CEN Item B.22 for the period ended December 31, 2022, indicates that the CM Commodity Index Fund had a NAV error during the period. However, the Staff did not locate disclosure of the financial statements related to such error. Please describe the nature and circumstances of the error, associated internal control implications, mitigating actions, and amounts reimbursed, if any. In addition, if amounts have been reimbursed, please explain, citing applicable US GAAP, Regulation S-X, and other accounting guidance, why the fund has not disclosed these reimbursement amounts in its financial statements.

Comment : The Staff notes that the Form N-CSR filed by the Fund: a. Does not provide a response to Items 4(i) and 4(j); b. References the wrong time period in response to Item 11(b) (it references the first fiscal half-year) ; and c. Item 4(d) of the Certifications does not refer to the correct time period (it references the second fiscal quarter). The Staff requests that the Fund re-file its Form N-CSR with responses to the missing Items referenced, corrects the time period for responses to Item 11(b) and Item 4(d) of the Certifications and confirms that there have been no material changes in internal control over financial reporting during the period since the wrong time period referenced in Item 11(b) and the fiscal year end of the Fund.

1. We note the Rule 13a–14(a)/15d–14(a) certifications included in Exhibits 31 omit paragraph 4(b), which refers to the design of internal control over financial reporting. Please amend your Form 10-K to include certifications containing the language precisely as set forth in Item 601(b)(31)(i) of Regulation S-K. Your amendment may include the cover page, explanatory note, signature page, and paragraphs 1, 2, 4 and 5 of the certification. Refer to Question 246.13 of the Regulation S-K C&DIs for guidance.

1. Although you disclose that management carried out an evaluation of the effectiveness of your disclosure controls and procedures, we note that you do not provide an effective conclusion pursuant to Item 307 of Regulation S-K. Please revise to disclose management's conclusions regarding the effectiveness of your disclosure controls and procedures.

2. You state that you believe that your reporting obligation was suspended automatically on October 1, 2023 in connection with your prior registration statement on Form F-1 that went effective by operation of law on April 17, 2023. Please qualify your belief here and in the risk factor discussion with the fact that you never filed a Form 20-F during the year that your registration statement went effective through operation of law creating uncertainty that you complied with the reporting requirements of Section 15(d) of the Exchange Act. See Exchange Act Rule Compliance and Disclosure Interpretation Question 153.03. In addition, please expand your risk factor to address the potential impact of failing to file the Form 20-F on the effectiveness of your disclosure controls and procedures.

2. Properties, at 61-87, relating to Nevada Gold Mines (NGM), of the Form 10-K filed with the Commission by Newmont Corporation on February 29, 2024. Securities and Exchange Commission May 14, 2024 Page 8 For our reporting purposes, we start with operator mineral resource and mineral reserves disclosure. We evaluate which portion of the reported mineral resources and mineral reserves is subject to our royalty or streaming interest. We then evaluate whether operator reporting of mineral resources is inclusive or exclusive of mineral reserves. If the reporting is inclusive, we subtract tonnage and metal in mineral reserves from the mineral resources, leaving the exclusive portion of mineral resources. We then standardize the information to metric units for reporting. For material properties, we tabulate mineral resources and mineral reserves according to the form specified in SK 1300,…

4. We note your response to prior comment 14. Please revise your disclosure to elaborate upon the nature of the remediation measures and their implementation status for the identified material weaknesses in Learn CW’s internal control over financial reporting.

2. We note the disclosure that you conducted an evaluation of your disclosure controls and procedures; however, you did not clearly disclose management's conclusions. In this regard, please tell us and revise your future filings to disclose management's conclusion on whether your disclosure controls and procedures were effective at the end of the period. Refer to the guidance in Item 307 of Regulation S-K. ​

1. We note your disclosure that Management’s Report on Internal Controls Over Financial Reporting has been omitted due to the transition period established by the rules of the SEC for newly public companies. Please explain to us how you determined you were eligible for this exemption or revise your filing accordingly.

1. Considering you filed an annual report on Form 10-K for the year ended December 31, 2022 on February 16, 2023, please clarify why you did not provide management’s annual report on internal control over financial reporting in your Form 10-K for the year ended December 31, 2023. Alternatively, amend your Form 10-K for the year ended December 31, 2023 to include management’s annual report on internal control over financial reporting pursuant to Item 308 of Regulation S-K. To the extent you file an amendment, tell us the basis for your conclusion that your disclosure controls and procedures were effective as of December 31, 2023 when you failed to provide management’s annual report on internal control over financial reporting or revise your disclosure accordingly. Vitesse Energy, Inc. • 9200 East Mineral Ave, Suite 200 • Centennial, CO 80112

2. Please file amended certifications of your chief executive officer and chief financial officer to include paragraph 4(b) of the certifications required to comply with Item 601(b)(31) of Regulation S-K regarding the design of internal control over financial reporting.

11. Comment : The Staff notes that Item 4C of the Certifications pursuant to Rule 30a-2(a) under the 1940 Act and Section 302 of the Sarbanes-Oxley Act (the “Certifications”) reference the evaluation of the effectiveness of the disclosure controls and procedures as of a date within 120 days of the date of the annual report. The Staff notes that these evaluations are required to be dated within 90 days of the report. Please file an amended Form N-CSR which includes Certifications that are dated within 90 days of the amended filing.

1. As previously requested in prior comment 1, revise to disclose that the material weakness resulted in ineffective disclosure controls and procedures and internal control over financial reporting.

Comment: Item B.22 of Form N-CEN for the period ended 12/31/2022 indicates that the Fund had an NAV error during the period; however, the Staff could not locate disclosure in the financial statements related to such error. Please describe the nature and circumstances of the error, associated internal control implications, mitigating actions, and amounts reimbursed, if any. In addition, if amounts have been reimbursed, please explain why the Fund has not disclosed these reimbursement amounts in its financial statements .

Comment: Item B.22 of Form N-CEN for the period ended 12/31/2022 indicates that the Fund had an NAV error during the period; however, the Staff could not locate disclosure in the financial statements related to such error. Please describe the nature and circumstances of the error, associated internal control implications, mitigating actions, and amounts reimbursed, if any. In addition, if amounts have been reimbursed, please explain why the Fund has not disclosed these reimbursement amounts in its financial statements .

1. We have read your response to prior comment 3, which includes various revisions to the amounts previously reported as audit and audit-related fees, and a description of the audit-related fees indicating these were paid to your auditors for reviews of your interim financial information and documents filed with the SEC. However, you have not provided an explanation for the numerical changes and the audit-related fees that you describe would ordinarily need to be reported in the category for audit fees. We encourage you to read the guidance on categorization of fees that resides in the seventh and eight paragraphs of Section II.H of SEC Release 33-8183, issued January 28, 2003. The following is a brief summary of that guidance. · Audit Fees - fees for services normally provided in connection with statutory and regulatory filings or engagements, including services necessary to perform an…

1. Please amend your filing to provide management's annual report on internal control over financial reporting as of December 31, 2023. Refer to Item 308(a) of Regulation S-K.

2. We note your disclosure on page 49 that you have implemented a remediation plan, described under Item 9A, Evaluation of Disclosure Controls and Procedures, which remediated the material weakness surrounding the preparation and review of the tax provision. Your disclosures under Changes in Internal Control over Financial Reporting on page 60 appear to indicate that your remediation plans are not yet implemented. Please revise the filing to fix the inconsistencies.

6. The Certifications pursuant to Rule 13a-14(a) or 15d-14(a) of the Securities Exchange Act Rules omit introductory language in paragraph 4 and 4(b) referencing to internal controls over financial reporting. Please amend the Form 10-K to provide a compliant Certification .

1. Please revise the following in an amendment to your Form 10-K: ● Pursuant to Item 307 of Regulation S-K, please clearly disclose the conclusions of your principal executive and principal financial officer regarding the effectiveness of your disclosure controls and procedures as of the end of the period covered by the report; and ● Pursuant to Item 308(a)(3) of Regulation S-K, please clearly disclose management’s assessment of the effectiveness of your internal control over financial reporting as of the end of your most recent fiscal year, including a statement as to whether or not internal control over financial reporting is effective.

Comment : The Auditor’s Internal Control Report filed as an exhibit to the Trust’s Form N-CEN for the fiscal year ended October 31, 2023 referenced only the Copley Fund. Please file an amended Form N-CEN to include an Internal Control Report for the other two funds in the Trust.

2. We note that you have included disclosure regarding your quality assurance and quality control review on page 53, although the revised disclosure appears to only encompass your material property. In a separate section, please also address the internal controls related to exploration and mineral resource and reserve estimation efforts that are applicable to all properties, as required by Item 1305 of Regulation S-K.

14. We note that you have identified material weaknesses in Learn CW’s, Innventure’s and AeroFlexx’s and internal control over financial reporting. Please revise to elaborate upon the nature of the remediation measures and their implementation status.

Comment 8 : The Internal Control Report from PriceWaterhouseCoopers in the September 30, 2023 Form N-CEN for The Advisors’ Inner Circle Fund III states “to the Board of Trustees of the Advisors’ Inner Circle Fund III and the Shareholders of the Funds listed in Appendix A”; however, Appendix A is not included. Please refile with the corresponding appendix stating the funds covered. Trust

3. Please amend your filing to include management's assessment of internal controls over financial reporting as of August 31, 2023.