0001193125-20-157094.txt : 20220204 0001193125-20-157094.hdr.sgml : 20220204 20200601150508 ACCESSION NUMBER: 0001193125-20-157094 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20200601 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SPDR INDEX SHARES FUNDS CENTRAL INDEX KEY: 0001168164 IRS NUMBER: 421537593 STATE OF INCORPORATION: MA FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE LINCOLN STREET CITY: BOSTON STATE: MA ZIP: 02111 BUSINESS PHONE: 617-664-1465 MAIL ADDRESS: STREET 1: ONE LINCOLN STREET CITY: BOSTON STATE: MA ZIP: 02111 FORMER COMPANY: FORMER CONFORMED NAME: SPDR INDEX SHARES FUNDS (Formerly streetTRACKS Index Shares Funds) DATE OF NAME CHANGE: 20070802 FORMER COMPANY: FORMER CONFORMED NAME: STREETTRACKS INDEX SHARES FUNDS (Formerly Fresco Index Shares Funds) DATE OF NAME CHANGE: 20041202 FORMER COMPANY: FORMER CONFORMED NAME: FRESCO INDEX SHARES FUNDS DATE OF NAME CHANGE: 20020225 CORRESP 1 filename1.htm SPDR Index Shares Funds

Morgan, Lewis & Bockius LLP

1111 Pennsylvania Avenue, NW

Washington, DC 20004

 

Via EDGAR Correspondence

 

June 1, 2020

 

Ms. Megan Miller

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:         SPDR® Index Shares Funds (File Nos. 333-92106 and 811-21145) (the “Registrant”)

Dear Ms. Miller:

This letter responds to comments you provided in a telephonic conversation with me on Wednesday, April 1, 2020, in connection with the SEC Staff’s Sarbanes-Oxley Act of 2002, as amended, review of certain of the Registrant’s filings. Summaries of the comments and responses thereto on behalf of the Registrant are provided below.

 

  1.

Comment: With respect to series of the Registrant that invest in futures contracts, in the notes to the financial statements, please expand the disclosure to explain where the initial margin with respect to the futures contracts is shown on the Statement of Assets and Liabilities.

Response: The Registrant will include additional disclosures in the Notes to Financial Statements in future shareholder reports to identify the location of the initial margin deposit for futures contracts – for securities deposited as initial margin, if any, as designated on the Schedule of Investments and cash deposited, if any, as shown on the Statement of Assets and Liabilities. The Registrant reported the initial margin deposit for futures contracts, separately, as “Cash at Broker” on the Statement of Assets and Liabilities in the September 30, 2019 annual report for the SPDR Portfolio Emerging Markets ETF, which was the only series of the Registrant that had futures contracts outstanding as-of fiscal year-end.

 

  2.

Comment: With respect to certain series of the Registrant, the Staff notes in the Schedule of Investments, investments are reported by country. As required by paragraph 20-21 of FASB ASC 825-10-50, in addition to the categorization chosen, any other significant type of concentration of credit risk should be reported. Please update the disclosure accordingly in future Form N-CSR filings.

Response:    The Registrant intends to include a supplemental summary table using a different categorization (i.e., a sector or industry table where the Schedule of Investments is presented by country) for certain international/global funds, including instances when there are significant concentrations of credit risk at a country and/or industry level. This supplemental summary table will be placed beneath the Schedule of Investments in future shareholder reports.

***************

Please do not hesitate to contact me at (202) 373-6133 if you have any questions concerning the foregoing.

 

  Sincerely,
  /s/  Beau Yanoshik
  Beau Yanoshik

cc:     Andrew DeLorme, Esq.

W. John McGuire, Esq.