0001162044-18-000103.txt : 20180323 0001162044-18-000103.hdr.sgml : 20180323 20180221131635 ACCESSION NUMBER: 0001162044-18-000103 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20180221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BERTOLET CAPITAL TRUST CENTRAL INDEX KEY: 0001216907 IRS NUMBER: 061680405 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 745 FIFTH AVE STREET 2: STE 2400 CITY: NEW YORK STATE: NY ZIP: 10151 BUSINESS PHONE: 212 605 7100 MAIL ADDRESS: STREET 1: 745 FIFTH AVE STREET 2: STE 2400 CITY: NEW YORK STATE: NY ZIP: 10151 CORRESP 1 filename1.htm                                                                    February 21,  2018

                                                                   February 21,  2018



U.S. Securities & Exchange Commission

3 World Financial Center

New York, NY 10281

Attn:  Megan Miller


Re: Bertolet Capital Trust (registrant)  File 811-21291



Dear Ms. Miller,


This letter is in response to your question to me on Feb. 13  on whether the recapture balance of $57,915 (on the NAV report labeled as a negative receivable from Advisor representing fees waived & expenses reimbursed by advisor that were subsequently recaptured) was available to advisor at Dec. 31, 2016. Since the recapture balance is available to the advisor, the amount has been settled and removed from the Fund’s books.


Registrant acknowledges that:

1.

Registrant is responsible for adequacy & accuracy of  filings reviewed by the staff; and

2.

Changes to disclosure in response to staff comments does not foreclose the Commission from taking any action with respect to the filing; and

3.

Registrant may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under United States federal securities laws.


If you have any questions or comments, please call me at 212-605-7100. Thank you very much.


                                                                           Sincerely,                                                                               


                                                               /s/       John E.  Deysher