M&A - Intrepid Capital Management Funds Trust

Form Type: CORRESP

Filing Date: 2024-11-01

Corporate Action: Acquisition

Type: Update

Accession Number: 000089706924002081

Filing Summary: Intrepid Capital Management Funds Trust, representing the Intrepid Small Cap Fund and the Intrepid Capital Fund, submitted a response to the SEC regarding comments on its Registration Statement on Form N-14. The acquisition involves costs borne by the Adviser, who will not be reimbursed. Trading costs will be covered by the Funds. After the acquisition, around 30% of the holdings from the Small Cap Fund will be reinvested in fixed income and equity securities. The Adviser holds capital loss carryforwards to offset any gains from repositioning trades, expecting to limit capital gain distributions. No shareholder approval is needed for the acquisition under Rule 17a-8 of the Investment Company Act, as no policies materially differ between funds. The Trustees concluded the acquisition would lower fees and expenses for shareholders, aiming for a beneficial outcome overall. Costs of the reorganization will not be disclosed as they are not deemed material since the Adviser will absorb these costs. Additionally, all necessary hyperlinks and legal disclosures have been reviewed and updated accordingly. Other operational aspects and potential impacts on performance, fees, and expenses were also clarified, ensuring that shareholders are informed about beneficial outcomes arising from the merger of funds.

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Form Type: N-14

Filing Date: 2024-09-20

Corporate Action: Acquisition

Type: New

Accession Number: 000089706924001878

Filing Summary: Intrepid Capital Management Funds Trust is conducting an acquisition of the assets and liabilities of the Intrepid Small Cap Fund by the Intrepid Capital Fund. The Board of Trustees approved the acquisition on August 20, 2024, which does not require shareholder approval. Upon completion, shareholders of the Intrepid Small Cap Fund will receive shares of the Intrepid Capital Fund equivalent to the net asset value of their holdings in the Small Cap Fund, resulting in the termination of the Small Cap Fund. The acquisition is expected to be effective on November [●], 2024, and is intended to be tax-free, allowing shareholders to avoid recognizing gains or losses at the time of the exchange. The Funds share similar management fees and investment objectives, focusing on long-term capital appreciation. Additional details and comparisons regarding the funds are outlined in the attached prospectus.

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