RUNN / Strategic Trust - Running Oak Efficient Growth ETF - Документы SEC, Годовой отчет, Доверенное заявление

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR 12(g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategic Trust (Exact name of registrant as specified in its charter) Delaware See Below (State of incorporation or organization) (I.

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Eversheds Sutherland (US) LLP 700 Sixth Street, NW, Suite 700 Washington, DC 20001-3980 D: +1 202.

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Eversheds Sutherland (US) LLP 700 Sixth Street, NW, Suite 700 Washington, DC 20001-3980 D: +1 202.

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Strategic Trust c/o U.S. Bank Global Fund Services 615 E. Michigan Street Milwaukee, WI 53202 April 19, 2024 VIA EDGAR TRANSMISSION Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Strategic Trust (the “Trust”) Securities Act Registration No. 333-258490 Investment Company Act Reg. No. 811-23723 Dear Sir or Madam: Pursuant to Ru

EX-99.25

NOTIFICATION OF THE REMOVAL FROM LISTING AND REGISTRATION OF THE STATED SECURITIES NYSE Arca hereby notifies the SEC of its intention to remove the entire class of the stated securities from listing and registration on the Exchange at the opening of business on December 19, 2023, pursuant to the provisions of Rule 12d2-2 (a).

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategic Trust (Exact name of registrant as sp

As filed with the Securities and Exchange Commission on September 29, 2023 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Strategic Trust (Exact name of registrant as sp

As filed with the Securities and Exchange Commission on June 6, 2023 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

Post Effective Amendment Number

Kelly Strategic ETF Trust 7887 East Belleview Ave., Suite 1100 Denver, Colorado 80111 September 21, 2022 VIA EDGAR TRANSMISSION EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Kelly Strategic ETF Trust (the ?Trust?) File Nos.: 333-258490 and 811-23723 Equity KellyShares Ladies and Gentlemen: Pursuant to Rule

Number of Shares

Kelly Residential & Apartment Real Estate ETF SCHEDULE OF INVESTMENTS May 31, 2022 (Unaudited) Number of Shares Value COMMON STOCKS 98.

Number of Shares

Kelly CRISPR & Gene Editing Technology ETF SCHEDULE OF INVESTMENTS May 31, 2022 (Unaudited) Number of Shares Value COMMON STOCKS 96.

Number of Shares

Kelly Hotel & Lodging Sector ETF SCHEDULE OF INVESTMENTS May 31, 2022 (Unaudited) Number of Shares Value COMMON STOCKS 99.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934 Kelly Strategic ETF Trust (Exact name of regist

As filed with the Securities and Exchange Commission on December 22, 2021 UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.

Kelly Strategic ETF Trust

AW 1 kellystrategicetftrustethe.htm AW Kelly Strategic ETF Trust 7887 East Belleview Ave., Suite 1100 Denver, Colorado 80111 December 3, 2021 VIA EDGAR TRANSMISSION EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Kelly Strategic ETF Trust File Nos.: 333-258490 and 811-23723 Kelly Ethereum Ether Strategy ETF

November 23, 2021

THREE CANAL PLAZA, SUITE 100 PORTLAND, MAINE 04101 November 23, 2021 VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management 100 F Street, N.

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X] Pre-Effective Amendment No. 3 [X] Post-Effective Amendment No. [ ] REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT

N-1A/A 1 kellyn1aa.htm N-1A/A As filed with the Securities and Exchange Commission on November 22, 2021 1933 Act Registration File No. 333-258490 1940 Act File No. 811-23723 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X] Pre-Effective Amendment No. 3 [X] Post-Effective Amendment No. [ ] and/or REGISTRATION STATEMENT U

Kelly Strategic ETF Trust Registration Statement on Form N-1A File No. 333- 258490 and 811- 23723 CIK - 0001873280

November 22, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.

Consent of Independent Registered Public Accounting Firm

EX-99.J.1 2 kellyetfcohenconsentletter.htm EX-99.J.I CONSENT OF INDEPENDENT AUDITOR CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation in this Registration Statement on Form N-1A of our report dated October 19, 2021, relating to the financial statement of Kelly Residential & Apartment Real Estate ETF, a series of Kelly Strategic ETF Trust, as of October

Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111

CORRESP 1 filename1.htm Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111 November 22, 2021 Mr. Ryan Sutcliffe U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Kelly Strategic ETF Trust (the “Trust”) Registration Statement on Form N-1A File Nos. 333-258490, 811-23723 Dear Mr. Sutcliffe: This let

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

Conduct Requirements 60. Trust Code of Ethics (?1940 Act Code of Ethics?) I.Purpose of the Code of Ethics The Kelly Strategic ETF Trust (the ?Trust?) has adopted this Code of Ethics (the ?Code?) to set forth guidelines and procedures that promote ethical practices and conduct by all of the Trust?s Access Persons, as defined below, and to ensure compliance with the federal securities laws. To the e

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

Kevin Kelly 7887 East Belleview Avenue, Suite 1100 Denver, CO 80111 September 27, 2021 Board of Trustees Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, CO 80111 To the Board of Trustees: I offer to purchase from Kelly Strategic ETF Trust (the ?Trust?) 6,667 shares of beneficial interest of the Kelly Strategic Residential & Apartment Real Estate ETF (the ?Fund?), a series of the Trust, at a price of $15.

Opinion and Consent of

November 15, 2021 Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111 Ladies and Gentlemen: We have acted as counsel for Kelly Strategic ETF Trust (the “Trust”) in connection with the offer by the Trust of an unlimited number of shares of beneficial interest of the Trust.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

FORM OF AUTHORIZED PARTICIPANT AGREEMENT [ ] This Authorized Participant Agreement (the ?Agreement?) is entered into by and between Foreside Fund Services, LLC (the ?Distributor?) and (the ?Participant?) and is subject to acceptance by [ ] (the ?[Transfer Agent/Index Receipt Agent]?), and is further subject to acknowledgement and agreement by Kelly Strategic ETF Trust (the ?Trust?), a series trust offering a number of portfolios of securities (each a ?Fund? and collectively the ?Funds?), solely with respect to Sections 4(c) and 12(c) herein.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

KELLY STRATEGIC ETF TRUST DISTRIBUTION PLAN (12b-1 Plan) The following Distribution Plan (the "Plan") has been adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended (the "Act"), by Kelly Strategic ETF Trust (the "Trust"), a Delaware statutory trust, on behalf of the series of the Trust listed on Schedule A as may be amended from time to time (each, a "Fund").

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

EX-99.D.2 3 ksm-penserrasubxadvisoryag.htm EX-99.D.2 SUBADVISORY AGMT PENSERRA CAPITAL MANAGEMENT LLC SUB-ADVISORY AGREEMENT Sub-Advisory Agreement (this “Agreement”) entered into as of the 2nd day of November, 2021, by and between Kelly Strategic Management, LLC, doing business as Kelly Intelligence, a Colorado limited liability company with its principal place of business at 7887 East Belleview

Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111

Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111 November 15, 2021 Mr.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

Code of Ethics Penserra Capital Management LLC March 2016 Penserra Capital Management LLC CODE OF ETHICS Adopted March 1, 2016 I.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

KELLY STRATEGIC MANAGEMENT, LLC CODE OF ETHICS August 11, 2021 KELLY STRATEGIC MANAGEMENT, LLC Code of Ethics Table of Contents TOC \o "1-2" \h \z \u Contents 1.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

TRANSFER AGENT SERVICING AGREEMENT THIS AGREEMENT is made and entered into as of the last day written on the signature page by and between KELLY STRATEGIC ETF TRUST, a Delaware statutory trust (the “Trust”) U.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

FUND ADMINISTRATION SERVICING AGREEMENT THIS AGREEMENT is made and entered into as of the last day written on the signature page by and between KELLY STRATEGIC ETF TRUST, a Delaware statutory trust (the ?Trust?) and U.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

ETF CUSTODY AGREEMENT THIS AGREEMENT is made and entered into as of the last date on the signature page, by and between KELLY STRATEGIC ETF TRUST, a Delaware statutory trust, (the “Trust”), and U.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

EX-99.E.1 4 kellystrategicinvestments-.htm EX-99.E.1 DISTRIBUTION AGMT ETF DISTRIBUTION AGREEMENT This Distribution Agreement (the “Agreement”) is made this day of 2021, by and between Kelly Strategic ETF Trust, a (the “Trust”) having its principal place of business at 7887 East Belleview Ave, Denver, CO, 80111, and Foreside Fund Services, LLC, a Delaware limited liability company (the “Distributo

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X] Pre-Effective Amendment No. 2 [X] Post-Effective Amendment No. [ ] REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT

As filed with the Securities and Exchange Commission on November 15, 2021 1933 Act Registration File No.

Consent of Independent Registered Public Accounting Firm

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the incorporation in this Registration Statement on Form N-1A of our report dated October 19, 2021, relating to the financial statement of Kelly Residential & Apartment Real Estate ETF, a series of Kelly Strategic ETF Trust, as of October 7, 2021, and to the references to our firm under the headings “Independent Registered Public Accounting Firm” and “Financial Statements” in the Statement of Additional Information.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

ETF FUND ACCOUNTING SERVICING AGREEMENT THIS AGREEMENT is made and entered into as of the last day written on the signature page by and between KELLY STRATEGIC ETF TRUST, a Delaware statutory trust (the ?Trust?) and U.

was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on

EX-99.D.1 2 kellystrategicetf-investme.htm EX-99.D.1 INVESTMENT ADV AGMT INVESTMENT ADVISORY AGREEMENT This Investment Advisory Agreement (“Agreement”) is made and entered into as of November 2, 2021, by and between Kelly Strategic ETF Trust, a Delaware statutory trust (“Trust”), on behalf of the funds listed on Appendix A, each a series of shares of the Trust (each, a “Fund” and, collectively, “F

Kelly Strategic ETF Trust Registration Statement on Form N-1A File No. 333- 258490 and 811- 23723 CIK - 0001873280

November 15, 2021 VIA EDGAR EDGAR Operations Branch Division of Investment Management Securities and Exchange Commission 100 F Street, N.

Power of Attorney for Mathew Patterson was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on October 15, 2021.

POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that the undersigned Trustee of Kelly Strategic ETF Trust (the ?Trust?) hereby appoints Kevin R.

Kelly Strategic ETF Trust

Kelly Strategic ETF Trust c/o U.S. Bank Global Fund Services 615 East Michigan Street Milwaukee, Wisconsin 53202 October 15, 2021 VIA EDGAR TRANSMISSION Ryan Sutcliffe United States Securities and Exchange Commission Division of Investment Management 100 “F” Street N.E. Washington, D.C. 20549 Re: Kelly Strategic ETF Trust Registration Statement on Form N-1A File Nos. 333-258490, 811-23723 Dear Mr.

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X] Pre-Effective Amendment No. 1 [X] Post-Effective Amendment No. [ ] REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT

As filed with the Securities and Exchange Commission on October 15, 2021 1933 Act Registration File No.

Amended and Restated Declaration of Trust was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on October 15, 2021.

AMENDED AND RESTATED DECLARATION OF TRUST of Kelly Strategic ETF Trust (a Delaware Statutory Trust) Dated as of October 1, 2021 TABLE OF CONTENTS AMENDED AND RESTATED DECLARATION OF TRUST ARTICLE I Name and Definitions 1 Section 1.

Power of Attorney for Ethan Powell was previously filed and is herein incorporated by reference from the Registration Statement on Form N-1A filed with the SEC on October 15, 2021.

POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that the undersigned Trustee of Kelly Strategic ETF Trust (the “Trust”) hereby appoints Kevin R.

Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111

CORRESP 1 filename1.htm Kelly Strategic ETF Trust 7887 East Belleview Avenue, Suite 1100 Denver, Colorado 80111 October 8, 2021 Mr. Ryan Sutcliffe U.S. Securities and Exchange Commission Division of Investment Management 100 F Street NE Washington, DC 20549 Re: Kelly Strategic ETF Trust Registration Statement on Form N-1A File Nos. 333-258490, 811-23723 Dear Mr. Sutcliffe: This correspondence is b

Kelly Strategic ETF Trust (the “Trust”) Registration Statement on Form N-1A File No. 333-258490

CORRESP 1 filename1.htm September 21, 2021 VIA EDGAR Mr. Ryan Sutcliffe Division of Investment Management Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Kelly Strategic ETF Trust (the “Trust”) Registration Statement on Form N-1A File No. 333-258490 Dear Mr. Sutcliffe: This letter sets forth responses to certain comments received in writing pertaining to the Trust’s Re

Declaration of Trust

DECLARATION OF TRUST of Kelly Strategic ETF Trust (a Delaware Statutory Trust) Dated as of June 21, 2021 {S2781378; 3} 4839-8805-2463, v.

istration Statement on Form N-1A filed with

BY-LAWS of Kelly Strategic ETF Trust (a Delaware Statutory Trust) Effective June 21, 2021 {S2780515; 3} 4843-5715-1215, v.

Registration Statement on Form N-1A

CERTIFICATE OF TRUST KELLY STRATEGIC ETF TRUST This Certificate of Trust is filed in accordance with the provisions of the Delaware Statutory Trust Act (12 Del.

Kelly Strategic ETF Trust

Kelly Strategic ETF Trust c/o U.S. Bank Global Fund Services 615 East Michigan Street Milwaukee, Wisconsin 53202 August 5, 2021 VIA EDGAR TRANSMISSION United States Securities and Exchange Commission Division of Investment Management 100 “F” Street N.E. Washington, D.C. 20549 Re: Kelly Strategic ETF Trust (the “Trust”) Ladies and Gentlemen: Pursuant to Section 8(b) of the Investment Company Act of

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X] Pre-Effective Amendment No. [ ] Post-Effective Amendment No. [ ] REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT O

N-1A 1 kellystrategicetftrustn-1a.htm N-1A As filed with the Securities and Exchange Commission on August 5, 2021 1933 Act Registration File No. 333- 1940 Act File No. 811-23723 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 [X] Pre-Effective Amendment No. [ ] Post-Effective Amendment No. [ ] and/or REGISTRATION STATEMENT

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940

N-8A 1 kellystrategicetftrustform.htm N-8A UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940 The undersigned investment company hereby notifies the U.S. Securities and Exchange Commission that it registers under and pursuant to the provisions of Section 8(a) of the Inve