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March 18, 2020
Via EDGAR and e-mail |
Mayer Brown LLP 1221
Avenue of the Americas
Main
Tel +1 212 506 2500 www.mayerbrown.com
Bradley W. Berman Direct Tel +1 212 506 2321 bberman@mayerbrown.com |
|
Edward P. Bartz Senior Counsel Division of Investment Management |
| Re: | m+ funds Trust, Series 3-2 Registration Statement on Form S-6 Filed March 18, 2020 File Nos.: 333-[●] and 811-23503 |
Dear Mr. Bartz:
On behalf of our client, m+ funds Trust, we submitted to the Securities and Exchange Commission on March 18, 2020 for filing the above-referenced registration statement for the m+ Growth [ ] Fund, m+ funds Trust, Series 3-2 (the “Trust”), a series of the m+ funds Trust.
The reference asset for the Trust will be the SPDR® S&P 500® ETF (the “Reference Asset”). The Trust will invest in a portfolio of exchange-traded options, and/or cash or cash equivalents. The Trust will provide investors with a percentage return equal to [ ]% of any percentage increase in the value of the Reference Asset, up to a maximum total return. Investors in the Trust may lose up to [ ]% of their investment.
Due to market instability, at the present time the Trust is not able to provide the maximum total return, leverage or maximum loss numbers in the registration statement.
Please feel free to call me at (212) 506-2321 with any questions.
Edward P. Bartz
U.S. Securities and Exchange Commission
March 18, 2020
Page 2
Sincerely,
/s/ Bradley Berman
Bradley Berman
| cc: | Oscar Loynaz Steve Houston Rep Poppell Anna T. Pinedo Mingli Wu |