0001379491-21-001026.txt : 20210419 0001379491-21-001026.hdr.sgml : 20210419 20210322112540 ACCESSION NUMBER: 0001379491-21-001026 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210322 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY ADVISOR SERIES IV CENTRAL INDEX KEY: 0000719451 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY INCOME TRUST DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: INCOME PORTFOLIOS DATE OF NAME CHANGE: 19920202 FORMER COMPANY: FORMER CONFORMED NAME: FIXED INCOME PORTFOLIOS DATE OF NAME CHANGE: 19920202 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY COVINGTON TRUST CENTRAL INDEX KEY: 0000945908 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FIDELITY ADVISOR SERIES I CENTRAL INDEX KEY: 0000722574 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 1130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 BUSINESS PHONE: 617-563-7000 MAIL ADDRESS: STREET 1: 245 SUMMER STREET CITY: BOSTON STATE: MA ZIP: 02210 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY ADVISOR SERIES 1 DATE OF NAME CHANGE: 19930706 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY BROAD STREET TRUST DATE OF NAME CHANGE: 19920820 FORMER COMPANY: FORMER CONFORMED NAME: FIDELITY ADVISOR EQUITY PORTFOLIO GROWTH DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm


COMMENTS RECEIVED ON FEBRUARY 25, 2021

FROM KEN ELLINGTON

FIDELITY ADVISOR SERIES I (File Nos. 002-84776 and 811-03785)

FIDELITY ADVISOR SERIES IV (File Nos. 002-83672 and 811-03737)

FIDELITY COVINGTON TRUST (File Nos. 033-60973 and 811-07319)



Fidelity MSCI Real Estate Index ETF (Form N-CSR Filing)

“Financial Statements”


C:

According to the Statement of Changes in Net Assets, Fidelity MSCI Real Estate Index ETF had a significant return of capital distribution. The Staff requests we explain why the Distributions Type by Calendar Quarter Ex-Date graph and the Dividends and Capital Gains Distributions chart on the fund’s website do not include amounts for return of capital.


R:

Disclosures on the website (Fidelity.com) represent the character of distributions under generally

accepted accounting principles (GAAP) and where applicable were supported by GAAP income at the time of the distribution and posting to the website. The financial statements for the same period reflect the tax character of distributions. The tax character of the distributions is also reported to shareholders on Form 1099-DIV.



Fidelity Covington Trust (Form N-CSR Filing)


C:

The amended form N-CSR filed on October 1, 2020 for Fidelity Covington Trust did not include an explanatory note or updated certifications. Please supplementally provide the reason for the amended filing and ensure that all future amended form N-CSR filings include an explanatory note and updated certifications.   


R:

The contents of the filing were accurate and unchanged. However, the metadata in the filing did not include the correct Series ID for the Fidelity Value Factor ETF and instead erroneously included the Series ID for the Fidelity International Value Factor ETF. We amended the filing on 10/1/20 to correct the Series ID metadata. Given that the amendment was administrative in nature we did not include an explanatory note nor update the certifications.