M&A - Investment Managers Series Trust III

Form Type: CORRESP

Filing Date: 2024-01-30

Corporate Action: Merger

Type: New

Accession Number: 000110465924008245

Filing Summary: This document outlines responses to comments from the SEC regarding the registration statement on Form N-14 for the planned reorganization of the FPA Global Equity ETF, transitioning from Northern Lights Fund Trust III to Investment Managers Series Trust III. The letter confirms that the registration statement’s necessary comments have been addressed, including confirmations about effective dates for other filings, fee structures, principal investment risks, and adjustments in financial highlights. Important aspects include the confirmation that the Acquiring Fund will succeed all capital loss carryforwards from the Acquired Fund, supporting its financial strategies moving forward. It is also noted that the annual fund operating expenses for both funds are detailed, indicating a slight difference in their expense structures due to economies of scale as they merge into a singular management entity.

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Form Type: N-14

Filing Date: 2023-12-27

Corporate Action: Merger

Type: New

Accession Number: 000110465923129760

Filing Summary: The document is a registration statement for FPA Funds Trust, filing Form N-14 with the SEC to solicit shareholder approval for a proposed Reorganization of the FPA Global Equity ETF, currently a series of Northern Lights Fund Trust III. This Reorganization involves the transfer of all assets from the Acquired Fund to a newly created Acquiring Fund, with shareholders receiving shares of the Acquiring Fund equivalent to the net asset value of their holdings in the Acquired Fund. The Reorganization aims to allow FPA to focus resources more effectively across its fund complex, with no expected increase in shareholder fees. The current management structure will remain, and tax consequences for shareholders are expected to be neutral, with no sales or redemption fees applied. Shareholders of record are invited to vote on this proposal at a Special Meeting scheduled for early 2024. Approval is necessary for the Reorganization to proceed, and if not approved, FPA will continue managing the Acquired Fund as it currently exists.

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