0001464413-23-000055.txt : 20230613 0001464413-23-000055.hdr.sgml : 20230613 20230613162420 ACCESSION NUMBER: 0001464413-23-000055 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 3 CONFORMED PERIOD OF REPORT: 20230331 FILED AS OF DATE: 20230613 DATE AS OF CHANGE: 20230613 EFFECTIVENESS DATE: 20230613 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Starboard Investment Trust CENTRAL INDEX KEY: 0001464413 IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-22298 FILM NUMBER: 231011485 BUSINESS ADDRESS: STREET 1: 116 SOUTH FRANKLIN STREET STREET 2: POST OFFICE BOX 69 CITY: ROCKY MOUNT STATE: NC ZIP: 27802-0069 BUSINESS PHONE: 252-972-9922 EXT.249 MAIL ADDRESS: STREET 1: 116 SOUTH FRANKLIN STREET STREET 2: POST OFFICE BOX 69 CITY: ROCKY MOUNT STATE: NC ZIP: 27802-0069 0001464413 S000038548 Matisse Discounted Closed-End Fund Strategy C000119000 Institutional Class Shares MDCEX 0001464413 S000061872 Matisse Discounted Bond CEF Strategy C000200403 Institutional Class MDFIX N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001464413 XXXXXXXX true false false N-1A S000038548 C000119000 S000061872 C000200403 Starboard Investment Trust 811-22298 0001464413 549300IGQEISLESO0528 116 SOUTH FRANKLIN STREET ROCKY MOUNT 27804 US-NC US 252-972-9922 The Nottingham Company 116 SOUTH FRANKLIN STREET ROCKY MOUNT 27804 252-972-9922 Records relating to services as Fund Accountant and Administrator UMB Bank, n.a. 928 Grand Boulevard 5th Floor Kansas City 64106 816-860-7780 Records relating to services as custodian Nottingham Shareholder Services, LLC 116 South Franklin Street PO Box 4365 Rocky Mount 27803-0365 252-984-3816 Records relating to services as Transfer Agent Deschutes Portfolio Strategies, LLC 4949 Meadows Road Suite 200 Lake Oswego 97035 503-210-3001 Records relating to services as Investment Advisor N N N N-1A 11 Y J. Buckley Strandberg N/A N James H. Speed, Jr. N/A N Theophilus Harper Pitt, Jr. N/A N Andrea Knoth N/A 116 South Franklin Street Rocky Mount 27804 XXXXXX Y N N N N N N Capital Investment Group, Inc. 008-31225 000014752 N/A N N Cohen and Company 925 N/A Y N N N N N N Matisse Discounted Closed-End Fund Strategy S000038548 549300ZSVXX0LZMMTD36 N 1 0 0 Fund of Funds N N N N N/A N/A N N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N Deschutes Portfolio Strategies, LLC 801-72044 000155424 N/A N Nottingham Shareholder Services, LLC 084-05687 5493004B2XJ9BX8S5061 N N N Refinitiv Financial Solutions N/A N Bloomberg Data Professional N/A N N UMB Bank, n.a. N/A N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Nottingham Shareholder Services, LLC 5493004B2XJ9BX8S5061 N N N The Nottingham Company 549300WSNC1UD33Z2P26 N N N Jones Trading Institutional Limited N/A N/A 213800DIYIKDWRCFOC55 1932 Aegis Capital Corp. N/A N/A N/A 1035 Clear Street LLC N/A N/A 549300KNQS43Y7TO3X67 26912 Interactive Brokers LLC N/A N/A 50OBSE5T5521O6SMZR28 1286 Wallachbeth Capital N/A N/A 549300R371KUKXEXC133 267 31760 3549084217 N 38713235 N N N N Matisse Discounted Bond CEF Strategy S000061872 549300VDRUKECI4KMZ43 N 1 0 0 Fund of Funds N N N N N/A N/A N N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N Deschutes Portfolio Strategies, LLC 801-72004 000155424 N/A N Nottingham Shareholder Services, LLC 084-05687 5493004B2XJ9BX8S5061 Y N N Bloomberg Data Professional N/A N Refinitiv Financial Solutions N/A N N UMB, n.a. VNOO6EITDJ2YUEBMSZ83 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N Nottingham Shareholder Services, LLC 5493004B2XJ9BX8S5061 Y N N The Nottingham Company 549300WSNC1UD33Z2P26 Y N N Capis Institutional Services N/A N/A 54930061X8RDWFDJIS05 2737 Clear Street LLC N/A N/A 549300KNQS43Y7TO3X67 72052 Interactive Brokers LLC N/A N/A 50OBSE5T5521O6SMZR28 4074 OPPENHEIMER & CO. N/A N/A N/A 480 Virtu ITG LLC N/A N/A 549300S41SMIODVIT266 1500 80843 80843 N 36727407 N N N N false false true false false false INTERNAL CONTROL RPT 2 mdcex.htm
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders of Matisse Discounted Closed‐End Fund Strategy
and the Board of Trustees of Starboard Investment Trust

In planning and performing our audit of the financial statements of Starboard Investment Trust comprising Matisse Discounted Closed‐End Fund Strategy (the “Fund”) as of and for the year ended March 31, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), 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 PCAOB. 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 March 31, 2023.

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.
Philadelphia, Pennsylvania June 7, 2023

C O H E N & C O M P A N Y , L T D .
800.229.1099 | 866.818.4538 fax | cohencpa.com


Registered with the Public Company Accounting Oversight Board
 INTERNAL CONTROL RPT 3 mdfix.htm
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders of Matisse Discounted Bond CEF Strategy
and the Board of Trustees of Starboard Investment Trust

In planning and performing our audit of the financial statements of Starboard Investment Trust comprising Matisse Discounted Bond CEF Strategy (the “Fund”) as of and for the year ended March 31, 2023, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), 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 PCAOB. 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 March 31, 2023.

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.
Philadelphia, Pennsylvania
June 7, 2023


C O H E N & C O M P A N Y , L T D .
800.229.1099 | 866.818.4538 fax | cohencpa.com


Registered with the Public Company Accounting Oversight Board