| Stradley Ronon Stevens & Young, LLP
Suite 2600
2005 Market Street
Philadelphia, PA 19103-7018
Telephone 215.564.8000
Fax 215.564.8120
www.stradley.com |
Don E. Felice
dfelice@stradley.com
(215) 564-8794
December 26, 2019
Via Edgar
Ms. Deborah O’Neal
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
| Re: | HC Capital Trust (“Registrant”) |
File Nos.: 33-87762 and 811-08918
Dear Ms. O’Neal:
This correspondence is being provided to you in response to your comments communicated during our December 18, 2019 telephone conversation with respect to the Registrant’s preliminary proxy statement filed on December 11, 2019.
The Registrant has made the changes that you requested in the proxy statement and confirms that all disclosure required by Item 22 of Schedule 14a, and particularly Item 22(a)(3)(iv), is included in the proxy statement.
Very truly yours,
Don E. Felice
4329876