Strategic Trust
c/o U.S. Bank Global Fund Services
615 E. Michigan Street
Milwaukee, WI 53202
April 19, 2024
VIA EDGAR TRANSMISSION
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
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| Re: | Strategic Trust (the “Trust”) |
| Securities Act Registration No. 333-258490 |
| Investment Company Act Reg. No. 811-23723 |
Dear Sir or Madam:
Pursuant to Rule 477 under the Securities Act of 1933, as amended, the Trust, on behalf of its series, the Kelly INDS Industrial & Logistics Real Estate ETF, Kelly SRVR Data Center & Tech Infrastructure ETF, Kelly US Cash Cow Leaders ETF and Kelly US Small Cap Cash Cow Leaders ETF, respectfully requests withdrawal of the following Post-Effective Amendments to the Trust’s Registration Statement on Form N-1A (the “Amendments”), which were filed for the purpose of registering shares of the Funds as new series of the Trust. No securities were sold in connection with the Amendments, and the Trust has determined not to proceed with the offering of the series at this time.
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Post Effective
Amendment Number | Date Filed | Submission Type | Accession Number |
| 4 | 11/17/2022 | 485APOS | 0000894189-22-008392 |
| 6 | 1/30/2023 | 485BXT | 0000894189-23-000706 |
| 7 | 3/1/2023 | 485BXT | 0000894189-23-001712 |
| 9 | 3/31/2023 | 485BXT | 0000894189-23-002370 |
| 10 | 4/28/2023 | 485BXT | 0000894189-23-003192 |
| 12 | 5/26/2023 | 485BXT | 0000894189-23-003953 |
| 13 | 6/26/2023 | 485BXT | 0000894189-23-004372 |
| 14 | 7/27/2023 | 485BXT | 0000894189-23-005011 |
| 17 | 8/24/2023 | 485BXT | 0000894189-23-006172 |
| 18 | 9/22/2023 | 485BXT | 0000894189-23-007107 |
| 21 | 10/23/2023 | 485BXT | 0000894189-23-007737 |
| 22 | 11/22/20023 | 485BXT | 0000894189-23-008533 |
| 23 | 12/22/2023 | 485BXT | 0000894189-23-009220 |
| 26 | 1/19/2024 | 485BXT | 0000894189-24-000287 |
| 27 | 2/20/2024 | 485BXT | 0000894189-24-001057 |
| 28 | 4/2/2024 | 485BXT | 0000894189-24-002207 |
The Adviser has determined that it will not proceed with these series. Based upon the foregoing, the Trust believes that withdrawal of the above-referenced Post-Effective Amendments is consistent with the public interest.
Pursuant to the requirements of Rule 478 of the 1933 Act, this application for withdrawal of the Post-Effective Amendment set forth above has been signed by the President of the Trust on this 19th day of April 2024.
If you have any questions or require further information, please contact Elaine Richards at 626-914-7363 or elaine.richards@usbank.com.
Sincerely,
/s/ Kevin Kelly
Kevin Kelly
President and Trustee
