0001752724-21-000743.txt : 20210108 0001752724-21-000743.hdr.sgml : 20210108 20210108093923 ACCESSION NUMBER: 0001752724-21-000743 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 5 CONFORMED PERIOD OF REPORT: 20201031 FILED AS OF DATE: 20210108 DATE AS OF CHANGE: 20210108 EFFECTIVENESS DATE: 20210108 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: 21515921 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 C000105788 Green Owl Intrinsic Value Fund GOWLX 0001437249 S000039824 Foundry Partners Fundamental Small Cap Value Fund C000123465 Institutional Class DRISX C000123466 Investor Class DRSVX 0001437249 S000039946 Sound Mind Investing Fund C000123868 Sound Mind Investing Fund SMIFX 0001437249 S000039947 SMI 50/40/10 Fund C000123869 SMI 50/40/10 Fund SMILX 0001437249 S000039948 SMI Dynamic Allocation Fund C000123870 SMI Dynamic Allocation Fund SMIDX 0001437249 S000042642 Dana Large Cap Equity Fund C000131829 Investor Class Shares DLCEX C000131830 Institutional Class Shares DLCIX 0001437249 S000051394 Dana Epiphany ESG Small Cap Equity Fund C000161987 Institutional Class Shares DSCIX 0001437249 S000063526 Dana Epiphany ESG Equity Fund C000205825 Institutional Class Shares ESGIX N-CEN 1 primary_doc.xml X0303 N-CEN LIVE 0001437249 XXXXXXXX 811-22208 false false false N-1A S000051394 true S000039946 true S000034367 true S000042642 true S000039824 true S000063526 true S000039947 true S000039948 true Valued Advisers Trust 811-22208 0001437249 549300W12YUPFS7QVT86 225 Pictoria Drive Suite 450 Cincinnati 45246 US-OH US 513-587-3400 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 Kovitz Investment Group Partners, LLC 115 S. LaSalle Street 27th Floor Chicago 60603-3801 312-334-7300 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 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 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 Ultimus Fund Distributors, LLC 225 Pictoria Drive Suite 450 Cincinnati 45246-1617 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 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 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 Dana Investment Advisors, Inc. 20700 Swenson Drive Suite 400 Waukesha 53186-0904 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 N N N N-1A 12 Y Mark J. Seger 001663313 Y Ira P. Cohen 001657889 N Andrea N. Mullins 002081957 N Kevin J. Patton 004631357 225 Pictoria Drive Suite 450 Cincinnati 45246-1617 XXXXXX N N N N N N N Ultimus Fund Distributors, LLC 008-52643 000104177 N/A N Unified Financial Securities, LLC 008-23508 000007868 N/A N Y Cohen and Company, Ltd. 925 N/A N N N N N N N Green Owl Intrinsic Value Fund S000034367 5493006OVKBWJ2CWYQ23 N 0 0 0 N/A N N N N N/A 0.00000000 0.00000000 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/A 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 11853.00000000 PERSHING LLC 008-17574 000007560 ZI8Q1A8EI8LQFJNM0D94 11853.33000000 HUNTINGTON NATIONAL BANK N/A 000012311 2WHM8VNJH63UN14OL754 376.00000000 12229.33000000 PERSHING LLC 008-17574 000007560 ZI8Q1A8EI8LQFJNM0D94 2305063.56000000 2305063.56000000 N 78197112.07000000 Uncommitted 1000000.00000000 N N N N Foundry Partners Fundamental Small Cap Value Fund S000039824 54930053SLTKYXVEOR98 N 2 0 0 N/A N N N N N/A 0.00000000 0.00000000 N/A 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/A 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 GOLDMAN SACHS & CO. 008-00129 000000361 FOR8UP27PHTHYVLBNG30 6782.15000000 CREDIT SUISSE SECURITIES LLC 008-00422 000000816 1V8Y6QCX6YMJ2OELII46 6460.54000000 SCHWAB (CHARLES) & CO. INC. 008-16514 000005393 549300ZP8XN77GK5BS04 6598.89000000 WELLS FARGO SECURITIES LLC 008-65876 000126292 VYVVCKR63DVZZN70PB21 4306.89999999 PIPER JAFFRAY & CO 008-15204 000000665 549300GRQCWQ3XGH0H10 5113.45000000 UBS SECURITIES LLC 008-22651 000007654 254900Y9HI2TG6D79N41 13910.30000000 RBC CAPITAL MARKETS 008-45411 000031194 549300LCO2FLSSVFFR64 7071.92000000 J P MORGAN SECURITIES LLC 008-35008 000000079 ZBUT11V806EZRVTWT807 8679.67000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 41330.72000000 OUTSET GLOBAL LLP 008-69657 000281065 549300CODTFC3OHCJJ49 6572.66000000 114172.74000000 0 Y 189505873.56000000 N N N N SMI Dynamic Allocation Fund S000039948 549300YDH2SRPN4R1J34 N 0 0 0 Fund of Funds N N N N N/A 0.00000000 0.00000000 N/A Y Y Y N SMI Advisory Services, LLC 801-64882 000137872 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N REFINITIV US LLC 213800HQORQAP68CJJ04 N/A 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 53265.30000000 53265.30000000 0 N 114906890.40000000 Uncommitted 5000000.00000000 N N N Dana Large Cap Equity Fund S000042642 549300E4P42ZUUBIPU02 N 2 0 0 N/A N N N N N/A 0.00000000 0.00000000 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/A 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 J.P. MORGAN SECURITIES INC. 008-35008 000000079 ZBUT11V806EZRVTWT807 1082.09999999 COWEN & COMPANY LLC 008-22522 000007616 549300WR155U7DVMIW58 4816.50000000 RAYMOND JAMES & ASSOCIATES INC 008-10999 000000705 U4ONQX15J3RO8XCKE979 5041.50000000 WOLFE RESEARCH 008-68406 000151850 25490055RCIM412FC286 6019.50000000 CAPITAL INSTITUTIONAL SERVICES, INC 008-22273 000007551 54930061X8RDWFDJIS05 6455.40000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 6068.40000000 KEEFE BRUYETTE & WOODS INC 008-10888 000000481 549300OM47DQV01G4854 4428.00000000 33911.40000000 0 Y 127330870.31000000 N N N N Sound Mind Investing Fund S000039946 549300L5369VQJ9OOL46 N 0 0 0 Fund of Funds N N N N N/A 0.00000000 0.00000000 Rule 12d1-1 (17 CFR 270.12d1-1) Y Y Y N SMI Advisory Services, LLC 801-64882 000137872 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N REFINITIV US LLC 213800HQORQAP68CJJ04 N/A 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 15737.30000000 15737.30000000 0 N 131962759.25000000 Uncommitted 5000000.00000000 N N N Dana Epiphany ESG Equity Fund S000063526 549300YMYIQKZYBXXY21 N 1 0 0 N/A N N N N N/A 0.00000000 0.00000000 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/A 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 RAYMOND JAMES & ASSOCIATES INC 008-10999 000000705 U4ONQX15J3RO8XCKE979 482.70000000 WOLFE RESEARCH 008-68406 000151850 25490055RCIM412FC286 195.75000000 CAPITAL INSTITUTIONAL SERVICES, INC 008-22273 000007551 54930061X8RDWFDJIS05 1004.55000000 J.P. MORGAN SECURITIES INC. 008-35008 000000079 ZBUT11V806EZRVTWT807 939.00000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 355.40000000 COWEN & COMPANY LLC 008-22522 000007616 549300WR155U7DVMIW58 735.15000000 KEEFE, BRUYETTE, & WOODS INC. 008-10888 000000481 549300OM47DQV01G4854 132.00000000 3844.55000000 0 Y 13018048.14000000 N N N N Dana Epiphany ESG Small Cap Equity Fund S000051394 5493005OGUYQV8N7HC77 N 1 0 0 N/A N N N N N/A 0.00000000 0.00000000 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/A 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 KEEFE, BRUYETTE, & WOODS INC. 008-10888 000000481 549300OM47DQV01G4854 1960.61000000 WOLFE RESEARCH 008-68406 000151850 25490055RCIM412FC286 380.20000000 COWEN & COMPANY LLC 008-22522 000007616 549300WR155U7DVMIW58 1540.34000000 CAPITAL INSTITUTIONAL SERVICES, INC 008-22273 000007551 54930061X8RDWFDJIS05 4744.91000000 J.P. MORGAN SECURITIES INC. 008-35008 000000079 ZBUT11V806EZRVTWT807 554.48000000 RAYMOND JAMES & ASSOCIATES INC 008-10999 000000705 U4ONQX15J3RO8XCKE979 1197.74000000 INSTINET LLC 008-23669 000007897 549300MGMN3RKMU8FT57 926.56000000 11304.84000000 0 Y 11614856.44000000 N N N N SMI 50/40/10 Fund S000039947 54930025EQMP6DCX0571 N 0 0 0 Fund of Funds N N N N N/A 0.00000000 0.00000000 N/A Y Y Y N SMI Advisory Services, LLC 801-64882 000137872 N/A N Ultimus Fund Solutions, LLC 084-05829 N/A N N N REFINITIV US LLC 213800HQORQAP68CJJ04 N/A 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 19326.43000000 11453.85000000 0 N 58585327.69000000 Uncommitted 5000000.00000000 N N N true INTERNAL CONTROL RPT 2 fp0060580_greenowl-g1aiii.htm

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, 2020, 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, 2020.

 

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.

 

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 23, 2020

 

INTERNAL CONTROL RPT 3 fp0060580_foundry-g1aiii.htm

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, 2020, 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, 2020.

 

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.

 

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 23, 2020

 

INTERNAL CONTROL RPT 4 fp0060580_smi-g1aiii.htm

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of Sound Mind Investing Fund, SMI Dynamic Allocation Fund, and

SMI 50/40/10 Fund Funds and

Board of Trustees of Valued Advisers Trust

 

In planning and performing our audit of the financial statements of 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, 2020, 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, 2020.

 

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.

 

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 23, 2020

INTERNAL CONTROL RPT 5 fp0060580_dana-g1aiii.htm

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of Dana Large Cap Equity Fund, Dana Epiphany ESG Small Cap Equity Fund (formerly Dana Small Cap Equity Fund), and Dana Epiphany ESG Equity Fund and

Board of Trustees of Valued Advisers Trust

 

In planning and performing our audit of the financial statements of Dana Large Cap Equity Fund, Dana Epiphany ESG Small Cap Equity Fund (formerly Dana Small Cap Equity Fund), and Dana Epiphany ESG Equity Fund (the “Funds”), each a series of Valued Advisers Trust, as of and for the year ended October 31, 2020, 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, 2020.

 

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.

 

COHEN & COMPANY, LTD.

Cleveland, Ohio

December 23, 2020