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0001193125-24-073552.txt : 20240604 0001193125-24-073552.hdr.sgml : 20240604 20240321121658 ACCESSION NUMBER: 0001193125-24-073552 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20240321 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COLUMBIA ACORN TRUST CENTRAL INDEX KEY: 0000002110 ORGANIZATION NAME: IRS NUMBER: 362692100 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 71 S. WACKER DRIVE, SUITE 2500 CITY: CHICAGO STATE: IL ZIP: 60606 BUSINESS PHONE: 3126349200 MAIL ADDRESS: STREET 1: 71 S. WACKER DRIVE, SUITE 2500 CITY: CHICAGO STATE: IL ZIP: 60606 FORMER COMPANY: FORMER CONFORMED NAME: LIBERTY ACORN TRUST DATE OF NAME CHANGE: 20010424 FORMER COMPANY: FORMER CONFORMED NAME: ACORN INVESTMENT TRUST DATE OF NAME CHANGE: 19940204 FORMER COMPANY: FORMER CONFORMED NAME: ACORN FUND INC DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COLUMBIA FUNDS SERIES TRUST CENTRAL INDEX KEY: 0001097519 ORGANIZATION NAME: IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 290 CONGRESS STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 800-345-6611 MAIL ADDRESS: STREET 1: 290 CONGRESS STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: NATIONS FUNDS TRUST DATE OF NAME CHANGE: 19991022 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Columbia Funds Series Trust II CENTRAL INDEX KEY: 0001352280 ORGANIZATION NAME: IRS NUMBER: 204384176 STATE OF INCORPORATION: MA FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 290 CONGRESS STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 800-345-6611 MAIL ADDRESS: STREET 1: 290 CONGRESS STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: RIVERSOURCE SERIES TRUST DATE OF NAME CHANGE: 20070928 FORMER COMPANY: FORMER CONFORMED NAME: RIVERSOURCE RETIREMENT SERIES TRUST DATE OF NAME CHANGE: 20060801 FORMER COMPANY: FORMER CONFORMED NAME: RiverSource Retirement Series Trust DATE OF NAME CHANGE: 20060206 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COLUMBIA FUNDS SERIES TRUST I CENTRAL INDEX KEY: 0000773757 ORGANIZATION NAME: IRS NUMBER: 363376651 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 290 CONGRESS STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 800-345-6611 MAIL ADDRESS: STREET 1: 290 CONGRESS STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: COLUMBIA FUNDS TRUST IX DATE OF NAME CHANGE: 20031107 FORMER COMPANY: FORMER CONFORMED NAME: LIBERTY STEIN ROE FUNDS MUNICIPAL TRUST DATE OF NAME CHANGE: 19991025 FORMER COMPANY: FORMER CONFORMED NAME: STEINROE MUNICIPAL TRUST DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm CORRESP

March 21, 2024

Mr. Mark Cowan

U.S. Securities and Exchange Commission

Division of Investment Management, Disclosure Review Office

100 F Street, N.E.

Washington, D.C. 20549

Re: Template Filing Relief Request Pursuant to Rule 485(b)(1)(vii) for

Columbia Acorn Trust

Columbia Funds Series Trust

Columbia Funds Series Trust I

Columbia Funds Series Trust II

(each, a Registrant and together, the Registrants)

Dear Mr. Cowan:

On December 8, 2023, pursuant to Rule 485(a)(1), we filed with the Commission Post-Effective Amendment No. 410 to the Registration Statement under the Securities Act of 1933, as amended (the “1933 Act”), and Amendment No. 414 to the Registration Statement under the Investment Company Act of 1940 (the “1940 Act”) of Columbia Funds Series Trust I (File Nos. 2-99356 and 811-04367), on behalf of its series, Columbia Real Estate Equity Fund (the “Template Filing”). The Template Filing was filed in order to register one new class of shares, Class S shares, to be offered by Columbia Real Estate Equity Fund.

The Registrants, on behalf of the funds listed in Exhibit A (the “Replicate Funds”), intend to offer Class S shares to the investing public pursuant to prospectuses that are expected to be effective on or before October 1, 2024 (the “Effective Date”). Normally, this would require each Registrant to file an amended registration statement under Rule 485(a)(1) with respect to each impacted series fund. However, because the disclosure pertaining to the new share class for all impacted series funds will be identical to the corresponding disclosure in the Template Filing, we respectfully request permission to file a registration statement (the “Replicate Filing”) for each of the Replicate Funds pursuant to Rule 485(b)(1)(vii) under the 1933 Act on or before October 1, 2024. Any disclosure changes resulting from the staff’s review of the Template Filing related to Class S shares, will be incorporated into the Replicate Filings, as applicable. We note that the registration statements of the Registrants were last reviewed as set forth in the following table:


Registrant	1933 Act #	1940 Act #	Most Recent 485(a)(1) filing
Columbia Acorn Trust	002-34223	811-01829	2/28/2018
Columbia Funds Series Trust	333-89661	811-09645	6/29/2022
Columbia Funds Series Trust I	002-99356	811-04367	12/8/2023
Columbia Funds Series Trust II	333-131683	811-21852	10/19/2022

In support of this request, the Registrants, on behalf of each of the Replicate Funds, make the following representations:

•

The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the Replicate Filings.

•

The Replicate Filings incorporate changes made to the disclosure included in the Template Filing to resolve any staff comments thereon.

•

The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b) under the 1933 Act.

If you have any questions, please contact either me at 212-850-1703 or Anna Butskaya at 612-671-4993.

Sincerely,

/s/ Joseph D’Alessandro

Joseph D’Alessandro

Vice President and Group Counsel

Ameriprise Financial, Inc.

EXHIBIT A

Columbia Acorn Trust

Columbia Acorn Fund

Columbia Acorn International

Columbia Acorn International Select

Columbia Thermostat Fund

Columbia Funds Series Trust

Columbia California Intermediate Municipal Bond Fund

Columbia Capital Allocation Moderate Aggressive Portfolio

Columbia Convertible Securities Fund

Columbia Large Cap Enhanced Core Fund

Columbia Large Cap Growth Opportunity Fund

Columbia Overseas Value Fund

Columbia Select Large Cap Equity Fund

Columbia Select Mid Cap Value Fund

Columbia Short Duration Municipal Bond Fund

Columbia Short Term Bond Fund

Columbia Small Cap Value Fund II

Columbia Funds Series Trust I

Columbia Adaptive Risk Allocation Fund

Columbia Balanced Fund

Columbia Bond Fund

Columbia Contrarian Core Fund

Columbia Corporate Income Fund

Columbia Dividend Income Fund

Columbia Emerging Markets Fund

Columbia Global Technology Growth Fund

Columbia High Yield Municipal Fund

Columbia Intermediate Duration Municipal Bond Fund

Columbia International Dividend Income Fund

Columbia Large Cap Growth Fund

Columbia Oregon Intermediate Municipal Bond Fund

Columbia Select Large Cap Growth Fund

Columbia Select Mid Cap Growth Fund

Columbia Small Cap Growth Fund

Columbia Small Cap Value Fund I

Columbia Strategic Income Fund

Columbia Tax-Exempt Fund

Columbia Total Return Bond Fund

Columbia Funds Series Trust II

Columbia Dividend Opportunity Fund

Columbia Flexible Capital Income Fund

Columbia Floating Rate Fund

Columbia Global Value Fund

Columbia High Yield Bond Fund

Columbia Income Opportunities Fund

Columbia Mortgage Opportunities Fund

Columbia Select Large Cap Value Fund

Columbia Seligman Global Technology Fund

Columbia Seligman Technology and Information Fund

Columbia Strategic Municipal Income Fund