 | K&L GatesLLP 70 West Madison Street Suite 3100 Chicago, IL 60602-4207 | |||
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MARK R. GREER
312.807.4393
mark.greer@klgates.com
Direct Fax: 312.827.8010
June 26, 2014
VIA EDGAR
Ms. Laura Hatch
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
| Re: | Hewitt Series Trust (the “Trust”) |
Securities Act File No. 333-59221
Investment Company Act File No. 811-08885
Dear Ms. Hatch:
On behalf of the Trust and its sole series, the Hewitt Money Market Fund (the “Fund”), I am writing in response to the comment that I received from the staff of the U.S. Securities and Exchange Commission (the “Staff”) via a telephone conversation held on June 19, 2014 regarding the Staff’s recent review of the Fund’s annual shareholder report filed on Form N-CSR for the period ended December 31, 2013. For your convenience, the Staff’s comment has been reproduced below in bold typeface, and the Trust’s response immediately follows.
Staff Comment: The Trust’s annual shareholder report states the Trust has entered into an administration agreement (the “Agreement”) requiring its administrator to absorb certain Fund expenses. The Trust has thus indicated that, under the terms of the Agreement, the Fund is obligated to reimburse the administrator for any fees waived and expenses absorbed within three years to the extent that the reimbursement does not cause the total ordinary operating expenses of the Fund to exceed the expense limitation set forth in the Agreement. However, the Notes to the Financial Statements (the “Notes”) of the Fund’s annual shareholder report only disclose the administrator’s obligation to waive fees or absorb expenses; the Notes do not disclose the Fund’s obligation to reimbursement expenses. In future reports to shareholders, please also include: (1) disclosure in the Notes discussing the terms of the Fund’s reimbursement obligations under the Agreement, and (2) the total dollar amounts, if any, subject to reimbursement pursuant to the Agreement or that have been reimbursed.
Ms. Laura Hatch
June 26, 2014
Page 2
Response: After discussing this matter with management to the Trust, we hereby confirm that, in future reports to shareholders, the Trust will disclose the terms of the Fund’s reimbursement obligations under the Agreement, as well as any dollar amounts subject to reimbursement pursuant to the Agreement or that have been reimbursed.
We believe that this information responds to your comment. Please call me at (312) 807-4393 to confirm the adequacy of our response.
| Sincerely, |
| /s/ Mark R. Greer |
| Mark R. Greer |
cc: Douglas S. Keith
Alan Goldberg, Esq.
HEWITT SERIES TRUST
4 OVERLOOK POINT
LINCOLNSHIRE, IL 60069
June 26, 2014
BY EDGAR
Ms. Laura Hatch
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Hewitt Series Trust
Securities Act Registration No. 333-59221
Investment Company Act Registration No. 811-08885
On behalf of the Hewitt Series Trust (the “Trust”), we hereby make the following representations:
(i) The Trust is responsible for the adequacy and accuracy of the disclosure in its filings with the Securities and Exchange Commission (the “Commission”);
(ii) Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the Trust’s filings; and
(iii) The Trust acknowledges that it may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| HEWITT SERIES TRUST | ||
| By: | /s/ Douglas S. Keith | |
| Name: | Douglas S. Keith | |
| Title: | Treasurer | |