Beau Yanoshik
Partner
+1.202.373.6133
beau.yanoshik@morganlewis.com
via EDGAR Correspondence
January 28, 2021
Ms. Jaea Hahn
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | SSGA Active Trust (the “Registrant”); SEC File Nos. 333-173276 and 811-22542; Post-Effective Amendment No. 163 to the Registrant’s Registration Statement on Form N-1A (“Amendment No. 163”) |
Dear Ms. Hahn:
This letter responds to comments you provided in a telephonic conversation with me on Wednesday, January 6, 2021, with respect to Amendment No. 163. Amendment No. 163 was filed on November 20, 2020 and included disclosure with respect to the SPDR Nuveen Municipal Bond ETF (the “Fund”), a series of the Registrant, as set forth in the Prospectus and Statement of Additional Information filed as part of Amendment No. 163.
Summaries of the comments with respect to the Fund, and responses thereto on behalf of the Registrant, are provided below. All page references refer to the pages in Amendment No. 163. Capitalized terms not defined herein should be given the meaning provided in Amendment No. 163.
Prospectus
| 1. | Comment: Please provide a completed draft of the Fund’s fee table and example information prior to effectiveness. |
Response: The completed fee and example tables are included in Appendix A to this correspondence.
| 2. | Comment: Please identify supplementally the broad-based securities index the Fund intends to use. |
Response: The Fund currently intends to use the Bloomberg Barclays 3-15 Year Blend (2-17) Municipal Bond Index as its broad based securities index.
| Morgan, Lewis & Bockius LLP | ||||||
| 1111 Pennsylvania Avenue, NW | ||||||
| Washington, DC 20004 |
+1.202.739.3000 | |||||
| United States |
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***************
Please do not hesitate to contact the undersigned 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.
Appendix A
FEES AND EXPENSES OF THE FUND
The table below describes the fees and expenses that you may pay if you buy, hold and sell shares of the Fund (“Fund Shares”). You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the table and Example below.
ANNUAL FUND OPERATING EXPENSES (expenses that you pay each year as a percentage of the value of your investment):
| Management fees |
0.40 | % | ||
| Distribution and service (12b-1) fees |
None | |||
| Other expenses1 |
0.00 | % | ||
| Total annual Fund operating expenses |
0.40 | % |
| 1 | “Other Expenses” are based on estimated amounts for the current fiscal year. |
EXAMPLE:
This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated, and then sell all of your Fund Shares at the end of those periods. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses remain the same. Although your actual costs may be higher or lower, based on these assumptions your costs would be:
| Year 1 |
Year 3 | |||
| $41 |
$ | 128 | ||