SEWARD & KISSEL LLP
One Battery Park Plaza
New York, New York 10004
Telephone: (212) 574-1200
Facsimile: (212) 480-8421
| July 11, 2018 |
Ms. Lauren Hamilton
Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review Office
3 World Financial Center
New York, NY 10281
| Re: | Centre Funds: Registration Statement on Form N-14 | ||
| File No. 333-225484 | |||
Ms. Hamilton:
Pursuant to your request, and in response to our telephone conversations on June 26, 2018 and July 10, 2018, enclosed with this letter are separate pages that will be incorporated into the combined Proxy Statement/Prospectus or Statement of Additional Information relating to the proposed reorganization of Centre Active U.S. Tax Exempt Fund, a series of Centre Funds (the “Trust”), into Centre Global Infrastructure Fund, another series of the Trust, as described in the above-referenced Registration Statement on Form N-14, which was filed with the Securities and Exchange Commission on June 7, 2018. The pages reflect the proposed changes we discussed in response to the Staff’s comments.
Please feel free to call me with any questions at (212) 574-1598.
| Sincerely, | ||
| /s/ Keri E. Riemer | ||
| cc: | James A. Abate | |
