Morgan, Lewis & BockiusLLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004
Tel. +1.202.739.3000
Fax: +1.202.739.3001
www.morganlewis.com
Christopher D. Menconi
Partner
+1.202.373.6173
cmenconi@morganlewis.com
January 23, 2017
Kim McManus
Senior Attorney
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | World Currency Gold Trust |
| Amendment No. 6 to Registration Statement on Form S-1 |
| Filing Date: January 20, 2017 |
| File No. 333-206640 |
Dear Ms. McManus:
This letter is submitted by World Currency Gold Trust (the “Registrant”) in response to comments that Jennifer Monick provided to the undersigned today via telephone relating to the above-referenced filing by the Registrant. Concurrently with the submission of this letter, the Registrant is filing Amendment No. 7 to its Form S-1 via EDGAR (the “Registration Statement”). Set forth below in italics are the Staff’s oral comments, together with the Registrant’s responses. Capitalized terms not defined herein should be given the meaning provided in the Registration Statement.
Statement of Financial Condition, page F-3
| 1. | We note your response to comment 4 of our comment letter dated January 19, 2017. We continue to believe that you should revise the filing to include audited financial statements for the Trust. |
| RESPONSE: The filing has been revised to include audited financial statements for the Trust. |
Kim McManus
Senior Attorney
U.S. Securities and Exchange Commission
Page 2
Notes to the Statement of Financial Condition, page F-6
| 2. | Please revise Note 5 to disclose the terms of redemption; specifically, please disclose any rights the Fund has to suspend or reject redemption requests. |
| RESPONSE: Note 5 has been revised to include the requested information. |
***
If you should have any questions, please do not hesitate to contact the undersigned at (202) 373-6173.
Very truly yours, |
/s/ Christopher D. Menconi |
Christopher D. Menconi |
| cc: | Gregory S. Collett, WGC USA Asset Management Company, LLC |
| Mr. Daniel Gordon, U.S. Securities and Exchange Commission |
| Ms. Jennifer Monick, U.S. Securities and Exchange Commission |
| Rahul Patel, Esq., U.S. Securities and Exchange Commission |