STEVEN HOWARD
showard@mrllp.com |
New York Office
800 Third Avenue, 24th Floor
New York, NY 10022
P 212.730.7700 F 212.730.7725 www.mrllp.com
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September 26, 2014
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1. | The Aspiration Funds have revised footnote four of the Prospectus to reflect all of the comments you gave me in our telephone conversation yesterday, as reflected in the attached redlined pages. |
2. | The Aspiration Funds undertake to have the comments referred to in 1 above incorporated in a Rule 497 filing to be made next week. |
3. | The Aspiration Funds agree supplementally that investments in mutual funds with share classes that charge 12b-1 fees will only be made if classes without 12b-1 fees are not available. |
1. | Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
2. | The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Trust from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
3. | The Trust may not assert staff comments as a defense in any proceeding initiated by the Commission under the federal securities laws of the United States. |
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Very truly yours,
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/s/ Steven R. Howard
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Steven R. Howard
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cc: | Andrei Cherny |
Shareholder Fees (Fees paid directly from your investment)
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Maximum sales charge (load) imposed on purchases (as a percentage of offering price)
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0.00%
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Maximum deferred sales charge (load) (as a percentage of amount redeemed)
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0.00%
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Redemption fee (as a percentage of amount redeemed)
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0.00%
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Annual Fund Operating Expenses
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(Expenses that you pay each year as a percentage of the value of your investment)
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Management fee1
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0.00%
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2.00%
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Distribution (Rule 12b-1) fees
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0.25%
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.25%
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Other expenses2
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1.29%
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1.29%
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Acquired fund fees and expenses3
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1.22%
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1.22%
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Total annual fund operating expenses
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2.76%
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4.76%
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Expense reimbursements
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1.04%
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1.04%
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Total annual fund operating expenses after fee waivers and expense reimbursements4
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1.72%
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3.72%
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1 | Investors in the Fund are clients of Aspiration Fund Adviser, LLC (the "Adviser") and may pay the Adviser a fee in the amount they believe is fair ranging from 0% to 2% of |
2 | Other expenses are based on estimated amounts for the Fund's first fiscal year. |
3 | These are expenses indirectly incurred by the Fund as a result of investing in one or more underlying investment companies (i.e., fees the Fund pays as a shareholder of the underlying investment company). Acquired fund fees and expenses are based on estimated amounts for the Fund's first fiscal year. |
4 | Aspiration Fund Adviser, LLC (the "Adviser") has signed an Expense Limitation Agreement (“Agreement”) with the Fund under which it agrees to limit annual fund operating expenses to 0.50% ("Maximum Operating Expense Limit). The Adviser will do this by |
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1 Year
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3 Years
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Assuming no payments to the Fund’s adviser
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$175
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$758
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Assuming a payment of 2% of the value of the shareholder’s account
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$374
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$1,341
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