MARK KARPE
Assistant Vice President, Counsel
Office: (949)219-3224
Fax: (949)219-3706
E-mail: Mark.Karpe@PacificLife.com
July 21, 2017
VIA EDGAR
Kathryn (Katie) Hinke, Esq.
Division of Investment Management
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
RE: | Supplemental Comment Letter |
Pacific Funds Series Trust |
(File Nos.333-61366,811-10385) |
Dear Ms. Hinke:
This supplemental letter is being provided pursuant to our conversation on July 20, 2017, during which the staff requested clarification regarding two responses in our letter dated July 14, 2017 (“Original Letter”), which responded to comments from the U.S. Securities and Exchange Commission staff on post-effective amendment (“PEA”) No. 134 to the registration statement of Pacific Funds Series Trust (the “Registrant”). Set forth below are the staff’s comments followed by Registrant’s responses.
1. | Comment:Please clarify Response #9 in the Original Letter by confirming supplementally that (i) the sales charges, waivers, reductions and discounts disclosed in the main part of the Class A, B, C, I, R, Advisor Class and Investor Class Prospectus apply to all financial intermediaries generally, while the waivers, reductions and discounts disclosed in the Appendix to the Prospectus apply only to the specific financial intermediary identified in the Appendix as of the date of the Prospectus, and (ii) to the extent that there are additional variations in sales charges, waivers, reductions or discounts as applicable to other financial intermediaries in the future, that the Prospectus and/or Appendix will be updated accordingly. |
Response: So confirmed. |
Page 1 of 2
Pacific Funds Series Trust – Supplemental Comment Response Letter
July 21, 2017
Page 2 of 2
2. | Comment: Please clarify Response #12 in the Original Letter by confirming supplementally that the 80% test for a Fund that is subject to Rule35d-1 is applied to the Fund’s net assets plus borrowings for investment purposes, as you disclose in the second paragraph under theGeneral Investment Informationsection. |
Response: So confirmed. |
If you have any questions or further comments, please feel free to contact me at (949)219-3224.
Sincerely,
/s/ Mark Karpe
Mark Karpe
cc: | Robin S. Yonis, Esq., Pacific Life Fund Advisors LLC |
Laurene MacElwee, Pacific Life Fund Advisors LLC |
Audrey L. Cheng, Esq., Pacific Life Insurance Company |
Anthony H. Zacharski, Esq., Dechert LLP |
Rachael Schwartz, Esq., Schiff Hardin LLP |