OFI Global Asset Management, Inc.
225 Liberty Street
New York, New York 10281-1008
October 20, 2017
Via Electronic Transmission
Mark Cowan, Esq.
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549
Re: | OFI SteelPath Series Trust – Oppenheimer SteelPath MLP & Energy Infrastructure Fund |
Registration Statement on Form N-1A
File Nos. 333-219598 and 811-23277
Dear Mr. Cowan:
We thank you for your comment, provided in an email to Mr. Taylor Edwards on October 19, 2017, to our response letter filed on October 17, 2017, on behalf of Oppenheimer SteelPath MLP & Energy Infrastructure Fund (the “Fund”), a series of OFI SteelPath Series Trust (the “Trust”). We have included your only comment in italics below, followed by our response. The comment referred to below corresponds to that provided in your August 29, 2017 comment letter, which was addressed previously in the Fund’s response letters filed on September 20, 2017 and October 17, 2017.
Prospectus
More About the Fund
About the Fund’s Investments
The Fund’s Principal Investment Strategies and Risks
27. | Please state that the Fund is concentrated in the energy industry. Also, please note that concentration risk disclosure should be specific to the energy industry. |
The Fund will revise the sentence that it proposed in its response letter filed October 17, 2017, as follows:
“The Fund will, under normal circumstances, concentrate in the group of industries that comprise the energy sector.”
With this change, we are tracking the precise language of the Fund’s fundamental investment restriction on industry concentration (which has been approved by the Fund’s Board of Trustees and the Fund’s initial shareholder).
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Please direct any questions you may have regarding the Registration Statement or this letter to the undersigned at:
Amy E. Shapiro
OFI Global Asset Management, Inc.
225 Liberty Street
New York, New York 10281-1008
212-323-5922
ashapiro@ofiglobal.com
Sincerely,
/s/ Amy E. Shapiro
________________________
Amy E. Shapiro
Vice President and
Associate General Counsel
cc: Cynthia Lo Bessette, Esq.
Joseph Benedetti, Esq.
Taylor V. Edwards, Esq.
Ropes & Gray LLP