0001752724-19-001192.txt : 20190111 0001752724-19-001192.hdr.sgml : 20190111 20190111144330 ACCESSION NUMBER: 0001752724-19-001192 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 5 CONFORMED PERIOD OF REPORT: 20181031 FILED AS OF DATE: 20190111 DATE AS OF CHANGE: 20190111 EFFECTIVENESS DATE: 20190111 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VALUED ADVISERS TRUST CENTRAL INDEX KEY: 0001437249 IRS NUMBER: 262762915 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-22208 FILM NUMBER: 19522171 BUSINESS ADDRESS: STREET 1: 225 PICTORIA DR. STREET 2: SUITE 450 CITY: CINCINNATI STATE: OH ZIP: 45246 BUSINESS PHONE: 513-587-3400 MAIL ADDRESS: STREET 1: 225 PICTORIA DR. STREET 2: SUITE 450 CITY: CINCINNATI STATE: OH ZIP: 45246 0001437249 S000034367 Green Owl Intrinsic Value Fund 0001437249 S000039824 Foundry Partners Fundamental Small Cap Value Fund 0001437249 S000039946 Sound Mind Investing Fund 0001437249 S000039947 SMI 50/40/10 Fund 0001437249 S000039948 SMI Dynamic Allocation Fund 0001437249 S000042642 Dana Large Cap Equity Fund 0001437249 S000051394 Dana Small Cap Equity Fund N-CEN 1 primary_doc.xml X0101 N-CEN LIVE 0001437249 XXXXXXXX 811-22208 false false false N-1A S000039946 true S000039824 true S000034367 true S000042642 true S000039948 true S000051394 true S000039947 true Valued Advisers Trust 811-22208 0001437249 549300W12YUPFS7QVT86 225 Pictoria Drive Suite 450 Cincinnati 45246 US-OH US 513-587-3400 Huntington National Bank 41 South High Street Columbus 43215-3406 800-322-4600 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations Unified Financial Securities, LLC 9465 Counselors Row Suite 200 Indianapolis 46240-3817 513-587-3400 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations Dana Investment Advisors, Inc. 20700 Swenson Drive Suite 400 Waukesha 53186-0904 612-376-2800 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations Kovitz Investment Group Partners, LLC 115 S. LaSalle Street 27th Floor Chicago 60603-3801 262-782-3631 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations Ultimus Fund Solutions, LLC 225 Pictoria Drive Suite 450 Cincinnati 45246 513-587-3400 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations Foundry Partners, LLC 323 Washington Ave North Suite 360 Minneapolis 55401-2206 800-796-4975 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations SMI Advisory Services, LLC 4400 Ray Boll Blvd. Columbus 47203-1760 800-796-4975 The accounts, books or other documents of the Registrant required to be maintained by Section 31(a) of the Investment Company Act of 1940, as amended, and the rules promulgated thereunder are kept in several locations Y N N N-1A 11 Y Andrea N. Mullins 002081957 N Ira P. Cohen 001657889 N Mark J. Seger 001663313 Y Brandon R. Kipp 006319686 225 Pictoria Drive Suite 450 Cincinnati 45246 XXXXXX N N N N N N Unified Financial Securities, LLC 008-23508 000007868 N/A N N Cohen and Company, Ltd. 925 N/A N N N N N N N SMI Dynamic Allocation Fund S000039948 549300YDH2SRPN4R1J34 Y 0 0 0 Fund of Funds N N N N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Y N Y N SMI Advisory Services, LLC 801-64882 000137872 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N WOLVERINE EXECUTION SERVICES L.L.C. 008-65336 000120719 549300J0EHU6M88PZ560 10362.40000000 10362.40000000 0.00 N 150086390.48000000 Uncommitted 5000000.00000000 N N N Foundry Partners Fundamental Small Cap Value Fund S000039824 54930053SLTKYXVEOR98 Y 2 0 0 N/A N N N N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Y N Y N Foundry Partners, LLC 801-76953 000164863 549300WBJAM78VONDL95 N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N OUTSET GLOBAL LLP 008-69657 000281065 549300CODTFC3OHCJJ49 3048.62000000 WEEDEN & CO. 008-37267 000016835 549300OYBLKSN8M8EW67 3602.33000000 RBC CAPITAL MARKETS 008-45411 000031194 549300LCO2FLSSVFFR64 2340.46999999 UBS SECURITIES LLC 008-22651 000007654 254900Y9HI2TG6D79N41 6564.70000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 17460.30000000 GOLDMAN SACHS & CO. 008-00129 000000361 FOR8UP27PHTHYVLBNG30 3154.20000000 CREDIT SUISSE SECURITIES LLC 008-00422 000000816 1V8Y6QCX6YMJ2OELII46 2592.79000000 WELLS FARGO SECURITIES LLC 008-65876 000126292 VYVVCKR63DVZZN70PB21 3169.46000000 BERNSTEIN (SANFORD C.), & CO., INC 008-52942 000104474 549300I7JYZHT7D5CO04 5769.11000000 SCHWAB (CHARLES) & CO. INC. 008-16514 000005393 549300ZP8XN77GK5BS04 1994.87000000 53645.55000000 0.00 Y 195604715.60000000 N N N N Dana Small Cap Equity Fund S000051394 5493005OGUYQV8N7HC77 Y 2 0 0 N/A N N N N N/A N/A N/A N/A Y Y Y N Dana Investment Advisors, Inc. 801-14828 000105879 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N WEEDEN & CO. 008-37267 000016835 549300OYBLKSN8M8EW67 51.04000000 CAPITAL INSTITUTIONAL SERVICES, INC 008-22273 000007551 54930061X8RDWFDJIS05 3079.18000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 6673.10000000 KEEFE, BRUYETTE, & WOODS INC. 008-10888 000000481 549300OM47DQV01G4854 2931.73000000 J.P. MORGAN SECURITIES INC. 008-35008 000000079 ZBUT11V806EZRVTWT807 106.98000000 RAYMOND JAMES & ASSOCIATES INC 008-10999 000000705 U4ONQX15J3RO8XCKE979 1283.52000000 COWEN & COMPANY LLC 008-22522 000007616 549300WR155U7DVMIW58 1996.14000000 16121.69000000 0.00 Y 21337284.64000000 N N N N Dana Large Cap Equity Fund S000042642 549300E4P42ZUUBIPU02 Y 2 0 0 N/A N N N N N/A N/A N/A N/A Y Y Y N Dana Investment Advisors, Inc. 801-14828 000105879 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N COWEN & COMPANY LLC 008-22522 000007616 549300WR155U7DVMIW58 1507.50000000 CAPITAL INSTITUTIONAL SERVICES, INC 008-22273 000007551 54930061X8RDWFDJIS05 20049.00000000 RAYMOND JAMES & ASSOCIATES INC 008-10999 000000705 U4ONQX15J3RO8XCKE979 8422.19000000 J.P. MORGAN SECURITIES INC. 008-35008 000000079 ZBUT11V806EZRVTWT807 5496.00000000 WEEDEN & CO. 008-37267 000016835 549300OYBLKSN8M8EW67 3678.00000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 13678.19000000 52830.88000000 0.00 Y 210766918.87000000 N N N N Green Owl Intrinsic Value Fund S000034367 5493006OVKBWJ2CWYQ23 Y 0 0 0 N/A N N N N N/A N/A N/A Rule 17e-1 (17 CFR 270.17e-1) Y Y Y N Kovitz Investment Group Partners, LLC 801-107054 000282241 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Kovitz Securities, LLC 008-66267 000129878 N/A 8976.00000000 PERSHING LLC 008-17574 000007560 ZI8Q1A8EI8LQFJNM0D94 8975.70000000 8975.70000000 0.00 N 83200976.81000000 Uncommitted 1000000.00000000 N N N N SMI 50/40/10 Fund S000039947 54930025EQMP6DCX0571 Y 0 0 0 Fund of Funds N N N N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Rule 17a-8 (17 CFR 270.17a-8) Y N Y N SMI Advisory Services, LLC 801-64882 000137872 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N WALLACHBETH CAPITAL LLC 008-67936 000147853 549300R371KUKXEXC133 38.00000000 WOLVERINE EXECUTION SERVICES L.L.C. 008-65336 000120719 549300J0EHU6M88PZ560 5391.15000000 5429.15000000 0.00 N 43609684.96000000 Uncommitted 5000000.00000000 N N N Sound Mind Investing Fund S000039946 549300L5369VQJ9OOL46 Y 0 0 0 Fund of Funds N N N N N/A N/A N/A Rule 12d1-1 (17 CFR 270.12d1-1) Y N Y N SMI Advisory Services, LLC 801-64882 000137872 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N N Huntington National Bank 2WHM8VNJH63UN14OL754 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N Ultimus Fund Solutions, LLC 084-05829 SEC File number N N N WALLACHBETH CAPITAL LLC 008-67936 000147853 549300R371KUKXEXC133 254.00000000 WOLVERINE EXECUTION SERVICES L.L.C. 008-65336 000120719 549300J0EHU6M88PZ560 16732.48000000 16986.48000000 0.00 N 193720921.06000000 Uncommitted 5000000.00000000 N N N false false true false false false INTERNAL CONTROL RPT 2 greenowl_g1aiii.htm

[LOGO APPEARS HERE]

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of Green Owl Intrinsic Value Fund and Board of Trustees of Valued Advisers Trust

 

In planning and performing our audit of the financial statements of Green Owl Intrinsic Value Fund (the "Fund"), a series of Valued Advisers Trust, as of and for the year ended October 31, 2018, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Fund's internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund's internal control over financial reporting. Accordingly, we express no such opinion.

 

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A fund's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP). A fund's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund's assets that could have a material effect on the financial statements.

 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

 

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions , to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund's annual or interim financial statements will not be prevented or detected on a timely basis.

 

Our consideration of the Fund's internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no deficiencies in the Fund's internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of October 31, 2018.

 

This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

/s/ Cohen & Company, LTD.

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 21, 2018

 

INTERNAL CONTROL RPT 3 foundry_g1aiii.htm

[LOGO APPEARS HERE]

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of Foundry Partners Fundamental Small Cap Value Fund and Board of Trustees of Valued Advisers Trust

 

In planning and performing our audit of the financial statements of Foundry Partners Fundamental Small Cap Value Fund (the "Fund"), a series of Valued Advisers Trust, as of and for the year ended October 31, 2018, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Fund's internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund's internal control over financial reporting . Accordingly, we express no such opinion.

 

The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A fund's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP). A fund's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund's assets that could have a material effect on the financial statements.

 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

 

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund's annual or interim financial statements will not be prevented or detected on a timely basis.

 

Our consideration of the Fund's internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no deficiencies in the Fund's internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of October 31, 2018.

 

This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

/s/ Cohen & Company, LTD.

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 21, 2018

 

INTERNAL CONTROL RPT 4 dana_g1aiii.htm

[LOGO APPEARS HERE]

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of Dana Funds and Board of Trustees of Valued Advisers Trust

 

In planning and performing our audit of the financial statements of Dana Funds comprising, Dana Large Cap Equity Fund and Dana Small Cap Equity Fund (the "Funds") , each a series of Valued Advisers Trust, as of and for the year ended October 31, 2018, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Funds' internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds' internal control over financial reporting . Accordingly, we express no such opinion.

 

The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A fund's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP). A fund's internal control over financial reporting Includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund's assets that could have a material effect on the financial statements.

 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

 

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Funds' annual or interim financial statements will not be prevented or detected on a timely basis.

 

Our consideration of the Funds' internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United Stat es). However, we noted no deficiencies in the Funds' internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of October 31, 2018.

 

This report is intended solely for the information and use of management and the Board of Trustees of the Funds and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties .

 

/s/ Cohen & Company, LTD.

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 21, 2018

 

INTERNAL CONTROL RPT 5 smi_g1aiii.htm

[LOGO APPEARS HERE]

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of SMI Funds and Board of Trustees of Valued Advisers Trust

 

In planning and performing our audit of the financial statements of SMI Funds comprising, Sound Mind Investing Fund, SMI Dynamic Allocation Fund, and SMI 50/40/10 Fund (the "Funds" ), each a series of Valued Advisers Trust, as of and for the year ended October 31, 2018, in accordance with the standards of the Public Company Accounting Oversight Board (United States), we considered the Funds' internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds' internal control over financial reporting . Accordingly, we express no such opinion.

 

The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A fund's internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP). A fund's internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund's assets that could have a material effect on the financial statements.

 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

 

A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis . A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Funds' annual or interim financial statements will not be prevented or detected on a timely basis.

 

Our consideration of the Funds' internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the Public Company Accounting Oversight Board (United States). However, we noted no deficiencies in the Funds' internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of October 31, 2018.

 

This report is intended solely for the information and use of management and the Board of Trustees of the Funds and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.

 

/s/ Cohen & Company, LTD.

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 21, 2018