MARK KARPE
Assistant Vice President, Counsel
Office: (949) 219-3224
Fax: (949) 219-3706
E-mail: Mark.Karpe@PacificLife.com
March 17, 2017
VIA EDGAR
Mr. Jason Fox, Staff Accountant
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE: | Pacific Funds Series Trust (the “Trust”), File No. 811-10385 |
N-CSR Filing |
Dear Mr. Fox:
This letter is being provided in response to oral comments received from the U.S. Securities and Exchange Commission staff on March 9, 2017, regarding the Trust’s March 31, 2016 Annual Report to Shareholders, which was filed on June 3, 2016 (SEC Accession No. 0001193125-16-612564). Set forth below is the staff’s comment followed by the Trust’s response.
Comment: Language in the financial statements implies that the recoupment of an expense reimbursement could extend beyond three years due to a reference to the Trust’s fiscal year end.
Response:The Trust’s policy is to allow recoupment of an expense reimbursement within three years from the time the reimbursement took place. The Trust will amend the disclosure language in the financial statements on a going forward basis to clarify this position.
If you have any questions or further comments regarding this matter, please contact me at (949) 219-3224.
Sincerely,
/s/ Mark Karpe
Mark Karpe
cc: | Robin S. Yonis, Esq., Pacific Life Fund Advisors LLC |
Trevor Smith, Pacific Life Insurance Company |
Laurene MacElwee, Pacific Life Fund Advisors LLC |
Anthony H. Zacharski, Esq., Dechert LLP |
Rachael Schwartz, Esq., Schiff Hardin LLP |