July 27, 2018 Via EDGAR | ATTORNEYS AT LAW 777 EAST WISCONSIN AVENUE MILWAUKEE, WISCONSIN 53202-5306 414.271.2400 TEL 414.297.4900 FAX www.foley.com WRITER’S DIRECT LINE 414.297.5596 pfetzer@foley.com Email CLIENT/MATTER NUMBER 082961-0143 |
Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 |
Re: | Hennessy Funds Trust |
Ladies and Gentlemen:
On behalf of Hennessy Funds Trust, a Delaware statutory trust (the “Company”), we are transmitting for filing a Registration Statement on Form N-14. The Registration Statement contains a Proxy Statement/Prospectus that provides information about (1) the acquisition of the assets and liabilities (other than the excluded liabilities) of the BP Capital TwinLine Energy Fund, a series of Professionally Managed Portfolios (“PMP”), by the Hennessy BP Energy Fund, a newly formed series of the Company and (2) the acquisition of the assets and liabilities (other than the excluded liabilities) of the BP Capital TwinLine MLP Fund, a series of PMP, by the Hennessy BP Midstream Fund, a newly formed series of the Company.
As the Hennessy BP Energy Fund is newly formed, with no assets or operations prior to consummation of the reorganization, and has the same investment objective and investment strategies as the BP Capital TwinLine Energy Fund, the BP Capital TwinLine Energy Fund is the accounting and performance survivor of the proposed reorganization (so, the Hennessy BP Energy Fund is the successor to the BP Capital TwinLine Energy Fund’s accounting and performance history). As the Hennessy BP Midstream Fund is newly formed, with no assets or operations prior to consummation of the reorganization, and has the same investment objective and investment strategies as the BP Capital TwinLine MLP Fund, the BP Capital TwinLine MLP Fund is the accounting and performance survivor of the proposed reorganization (so, the Hennessy BP Midstream Fund is the successor to the BP Capital TwinLine MLP Fund’s accounting and performance history).
Please call the undersigned at (414) 297-5596 should you have any questions regarding this filing.
Very truly yours,
/s/ Peter D. Fetzer
Peter D. Fetzer
/s/ Peter D. Fetzer
Peter D. Fetzer
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