Ultimus Managers Trust
225 Pictoria Drive, Suite 450
Cincinnati, OH 45246
February 7, 2024
VIA EDGAR CORRESPONDENCE
David Manion
Senior Staff Accountant
U.S. Securities and Exchange Commission
Division of Investment Management, Disclosure Review and Accounting Office
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Ultimus Managers Trust (the “Registrant”) |
File Nos. 333-180308; 811-22680
Dear Mr. Manion:
In a telephone conversation with me on February 2, 2024, you communicated the U.S. Securities and Exchange Commission staff’s (the “Staff”) comment on the Registrant’s Form N-CSRS filed on July 31, 2023 under the Investment Company Act of 1940, as amended, on behalf of its series the Q3 All-Season Systematic Opportunities Fund and the Q3 All Season Tactical Fund (each, a “Fund” and together, the “Funds”). A summary of the Staff’s comment, along with the Registrant’s response, is set forth below.
Comment 1. While the Form N-CSRS filing for the Funds included an exhibit disclosing the change in the Funds’ Independent Registered Public Accounting Firm from BBD LLP (“BBD”) to Cohen & Company, Ltd. (“Cohen”) following Cohen’s acquisition of BBD’s Investment Management Group, it did not include as an exhibit BBD’s agreement with the statements concerning its firm being made by the Trust pursuant to Item 304(a) of Regulation S-K (the “BBD Exhibit”). The Form N-CSRS for the Funds needs to be amended and re-filed to include the BBD Exhibit.
Response. The Registrant acknowledges the Staff’s comment and will re-file the Form N-CSRS to include the BBD Exhibit for the Funds. The Registrant will also amend and re-file the Form N-CSR, or Form NCRS, as applicable, for the series of the Registrant noted in Schedule A to this response, to include the BBD Exhibit.
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We believe that the foregoing has been responsive to the Staff’s comment. Please call the undersigned at 513-577-1693 if you wish to discuss this correspondence further.
Sincerely,
/s/ Karen Jacoppo-Wood
Karen Jacoppo-Wood
Secretary
cc: T. Heim, President of the Trust
D. Bauer, Treasurer of the Trust
G. Gosselink, Northern Lights Compliance Services, LLC
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Schedule A
Form N-CSRS for the Fiscal Period Ended April 30, 2023; Filed on July 6, 2023
(Accession No.: 0001580642-23-003482)
Westwood Quality Value Fund
Westwood Quality MidCap Fund
Westwood Quality SMidCap Fund
Westwood Quality SmallCap Fund
Westwood Quality AllCap Fund
Westwood Total Return Fund
Westwood Income Opportunity Fund
Westwood High Income Fund
Westwood Alternative Income Fund
Westwood SmallCap Growth Fund
Form N-CSRS for the Fiscal Period Ended May 31, 2023; Filed on July 31, 2023
(Accession No.: 0001580642-23-003871)
Q3 All-Season Active Rotation ETF
Q3 All-Season Systematic Opportunities Fund
Q3 All-Season Tactical Fund
Lyrical U.S. Value Equity Fund
Lyrical International Value Equity Fund
U.S. Value ETF
Form N-CSR for the Fiscal Year Ended May 31, 2023; Filed on August 3, 2023
(Accession No.: 0001580642-23-003980)
Adler Value Fund
Kempner Multi-Cap Deep Value Fund
Evolutionary Tree Innovators Fund
Karner Blue Biodiversity Impact Fund
Wavelength Fund
Form N-CSRS for the Fiscal Period Ended June 30, 2023; Filed on September 7, 2023
(Accession No.: 0001580642-23-004739)
Westwood Salient MLP & Energy Infrastructure Fund
Westwood Salient Global Real Estate Fund
Westwood Salient Select Income Fund
Westwood Broadmark Tactical Growth Fund
Westwood Broadmark Tactical Plus Fund
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