MEMORANDUM | ||
| TO: | Kathryn Hinke U.S. Securities and Exchange Commission | |
| FROM: | Emily J. Bennett Associate General Counsel | |
| DATE: | July 20, 2017 | |
SUBJECT: | Response to a supplement comment to the initial registration statement filed on Form N-14 on June 14, 2017, as amended on June 19, 2017, (the "Registration Statement") relating to the reorganization of the JNAM Guidance – Growth Fund, a series of Jackson Variable Series Trust ("JVST"), into the JNL Disciplined Moderate Growth Fund, a series of the JNL Series Trust (the "Registrant") File No.: 333-218726 | |
This memorandum addresses the U.S. Securities and Exchange Commission staff's (the "Commission Staff") supplemental comment to the Registration Statement received via telephone on July 20, 2017.
The comment is set forth below in italics, with the response immediately following.
| 1. | Please confirm supplementally that the total annual fund operating expense ratio and expense example provided in the Proxy Statement will not change as the result of the 12b-1 fee that will be effective on September 25, 2017 due to the offset referenced in the response to Comment 15 filed on July 18, 2017. |
RESPONSE: The Registrant confirms that the total annual fund operating expense ratio and expense example provided in the Proxy Statement will not change as the result of the 12b-1 fee that will be effective on September 25, 2017 due to the offset referenced in response to Comment 15 filed on July 18, 2017.
It is the Registrant's intention to respond fully to the Commission Staff's comment, and the Registrant believes that the response described above does so fully.
If you have any questions, please call me at 312-730-9730. Thank you for your prompt attention to this matter.
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