0001145549-22-075949.txt : 20221213
0001145549-22-075949.hdr.sgml : 20221213
20221213110207
ACCESSION NUMBER: 0001145549-22-075949
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 3
CONFORMED PERIOD OF REPORT: 20220930
FILED AS OF DATE: 20221213
DATE AS OF CHANGE: 20221213
EFFECTIVENESS DATE: 20221213
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: Investment Managers Series Trust
CENTRAL INDEX KEY: 0001318342
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FILING VALUES:
FORM TYPE: N-CEN
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-21719
FILM NUMBER: 221458857
BUSINESS ADDRESS:
STREET 1: 235 WEST GALENA STREET
CITY: MILWAUKEE
STATE: WI
ZIP: 53212
BUSINESS PHONE: 626-914-4141
MAIL ADDRESS:
STREET 1: 235 WEST GALENA STREET
CITY: MILWAUKEE
STATE: WI
ZIP: 53212
FORMER COMPANY:
FORMER CONFORMED NAME: Claymore Trust
DATE OF NAME CHANGE: 20050603
FORMER COMPANY:
FORMER CONFORMED NAME: Claymore Equity Trust
DATE OF NAME CHANGE: 20050218
0001318342
S000030132
Ironclad Managed Risk Fund
C000092548
Ironclad Managed Risk Fund
IRONX
0001318342
S000034478
Towle Deep Value Fund
C000105973
Towle Deep Value Fund
TDVFX
N-CEN
1
primary_doc.xml
X0404
N-CEN
LIVE
0001318342
XXXXXXXX
true
false
false
N-1A
S000030132
true
S000034478
true
INVESTMENT MANAGERS SERIES TRUST
811-21719
0001318342
549300ESWU4ZNAH5Y054
235 WEST GALENA STREET
MILWAUKEE
532123948
US-WI
US
4142992000
UMB FUND SERVICES, INC.
235 WEST GALENA STREET
MILWAUKEE
53212
4142992000
TRANSFER AGENT, FUND ACCOUNTANT AND CO-ADMINISTRATOR
MUTUAL FUND ADMINISTRATION, LLC
2220 E. ROUTE 66, SUITE 226
GLENDORA
91740
6269144141
CO-ADMINISTRATOR
UMB BANK, N.A.
928 GRAND BOULEVARD, 5TH FLOOR
KANSAS CITY
64106
8168601142
CUSTODIAN
TOWLE & CO.
50 SOUTH STEELE STREET
SUITE 1000
DENVER
80209
8889986953
ADVISER
IRONCLAD INVESTMENTS LLC
190 INDEPENDENCE LANE
SUITE 2D
MAITLAND
32751
3148220204
ADVISER
IMST DISTRIBUTORS, LLC
THREE CANAL PLAZA, SUITE 100
PORTLAND
04101
8662516920
DISTRIBUTOR
N
N
N-1A
54
Y
CHARLES H. MILLER
N/A
N
ASHLEY TOOMEY RABUN
N/A
N
WILLIAM H. YOUNG
N/A
N
JOHN P. ZADER
N/A
Y
MAUREEN QUILL
001421521
Y
MARTIN W. DZIURA
N/A
309 WOODRIDGE LANE
MEDIA
19063
XXXXXX
N
N
N
N
N
N
N
IMST DISTRIBUTORS, LLC
8-66389
000130745
N/A
N
N
TAIT, WELLER & BAKER LLP
00445
N/A
N
N
N
N
N
N
N
Ironclad Managed Risk Fund
S000030132
549300BTO328LME8TL55
N
1
0
0
N/A
N
N
N
N
N/A
N/A
N/A
Rule 32a-4 (17 CFR 270.32a-4)
Rule 12d1-4 (17 CFR 270.12d1-4)
Rule 18f-4 (17 CFR 270.18f-4)
Y
Y
Y
N
IRONCLAD INVESTMENTS LLC
801-71772
000154872
N/A
N
UMB FUND SERVICES, INC.
084-05792
N/A
Y
N
N
INTERCONTINENTAL EXCHANGE, INC.
5493000F4ZO33MV32P92
N
N
UMB BANK, NATIONAL ASSOCIATION
VNOO6EITDJ2YUEBMSZ83
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
UMB FUND SERVICES, INC.
084-05792
SEC File Number
Y
N
N
MUTUAL FUND ADMINISTRATION, LLC
N/A
N/A
Y
N
UMB FUND SERVICES, INC.
084-05792
SEC File Number
Y
N
N
INTERACTIVE BROKERS CORP.
8-53615
000117942
N/A
21890.000000000000
21890.000000000000
INTERACTIVE BROKERS CORP.
8-53615
000117942
N/A
799385662.000000000000
799385662.000000000000
N
106456571.000000000000
N
N
N
N
Towle Deep Value Fund
S000034478
549300EXKT1LTZE2ZC55
N
1
0
0
N/A
Y
N
N
N
N/A
N/A
N/A
Rule 32a-4 (17 CFR 270.32a-4)
Y
N
N
N
TOWLE & CO
801-16622
000110862
N/A
N
UMB FUND SERVICES, INC.
084-05792
N/A
Y
N
N
INTERCONTINENTAL EXCHANGE, INC.
5493000F4ZO33MV32P92
N
N
UMB BANK, NATIONAL ASSOCIATION
VNOO6EITDJ2YUEBMSZ83
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
UMB FUND SERVICES, INC.
084-05792
SEC File Number
Y
N
N
MUTUAL FUND ADMINISTRATION, LLC
N/A
N/A
Y
N
UMB FUND SERVICES, INC.
084-05792
SEC File Number
Y
N
N
Sanders Morris Harris, LLC
8-38325
000020580
254900ZNPYV465D1NZ47
145823.000000000000
Tourmaline Partners, LLC
8-68644
000154492
5493002XAV50EJHN6Y32
140172.000000000000
285995.000000000000
0.000000000000
Y
111341752.000000000000
N
N
N
N
true
INTERNAL CONTROL RPT
2
towle.txt
TOWLEINTERNALCONTROL
REPORT OF INDEPENDENT
REGISTERED PUBLIC
ACCOUNTING FIRM
To the Shareholders and
Board of Trustees of
Investment Managers Series Trust
Glendora, California 91740
In planning and performing our audit of
the financial statements of Towle Deep
Value Fund (the Fund), a series of
Investment Managers Series Trust, as of
and for the year ended September 30,
2022, in accordance with the standards
of the Public Company Accounting
Oversight Board (United States), we
considered their internal control over
financial reporting, including control
activities for safeguarding securities, as
a basis for designing our auditing
procedures for the purpose of expressing
our opinion on the financial statements
and to comply with the requirements of
Form N-CEN, but not for the purpose of
expressing an opinion on the
effectiveness of the Funds internal
control over financial reporting.
Accordingly, we express no such
opinion.
The management of the Fund is
responsible for establishing and
maintaining effective internal control
over financial reporting. In fulfilling
this responsibility, estimates and
judgments by management are required
to assess the expected benefits and
related costs of controls. A companys
internal control over financial reporting
is a process designed to provide
reasonable assurance regarding the
reliability of financial reporting and the
preparation of financial statements for
external purposes in accordance with
generally accepted accounting
principles. A companys internal control
over financial reporting includes those
policies and procedures that (1) pertain
to the maintenance of records that, in
reasonable detail, accurately and fairly
reflect the transactions and dispositions
of the assets of the company; (2) provide
reasonable assurance that transactions
are recorded as necessary to permit
preparation of financial statements in
accordance with generally accepted
accounting principles, and that receipts
and expenditures of the company are
being made only in accordance with
authorizations of management and
directors of the company; and (3)
provide reasonable assurance regarding
prevention or timely detection of
unauthorized acquisition, use or
disposition of a companys assets that
could have a material effect on the
financial statements.
Because of inherent limitations, internal
control over financial reporting may not
prevent or detect misstatements. Also,
projections of any evaluation of
effectiveness to future periods are
subject to the risk that controls may
become inadequate because of changes
in conditions, or that the degree of
compliance with the policies or
procedures may deteriorate.
A deficiency in internal control over
financial reporting exists when the
design or operation of a control does not
allow management or employees, in the
normal course of performing their
assigned functions, to prevent or detect
misstatements on a timely basis. A
material weakness is a deficiency, or
combination of deficiencies, in internal
control over financial reporting, such
that there is a reasonable possibility that
a material misstatement of the companys
annual or interim financial statements
will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal
control over financial reporting was for
the limited purpose described in the first
paragraph and would not necessarily
disclose all deficiencies in internal
control that might be material
weaknesses under standards established
by the Public Company Accounting
Oversight Board (United States).
However, we noted no deficiencies in
the Funds internal control over financial
reporting and its operation, including
controls for safeguarding securities,
which we consider to be material
weaknesses, as defined above, as of
September 30, 2022.
This report is intended solely for the
information and use of management,
Shareholders and Board of Trustees of
Investment Managers Series Trust and
the Securities and Exchange
Commission, and is not intended to be
and should not be used by anyone other
than these specified parties.
/s/ Tait, Weller & Baker LLP
TAIT, WELLER & BAKER LLP
Philadelphia, Pennsylvania
November 29, 2022
taitweller.com
To the Shareholders and
Board of Trustees of
Investment Managers Series Trust
Page Two
INTERNAL CONTROL RPT
3
ironx.txt
IRONCLADINTERNALCONTROL
REPORT OF INDEPENDENT
REGISTERED PUBLIC
ACCOUNTING FIRM
To The Shareholders and
Board of Trustees of
Investment Managers Series Trust
Glendora, California 91740
In planning and performing our audit of
the financial statements of Ironclad
Managed Risk Fund (the Fund), a series
of Investment Managers Series Trust, as
of and for the year ended September 30,
2022, in accordance with the standards
of the Public Company Accounting
Oversight Board (United States), we
considered their internal control over
financial reporting, including control
activities for safeguarding securities, as
a basis for designing our auditing
procedures for the purpose of expressing
our opinion on the financial statements
and to comply with the requirements of
Form N-CEN, but not for the purpose of
expressing an opinion on the
effectiveness of the Funds internal
control over financial reporting.
Accordingly, we express no such
opinion.
The management of the Fund is
responsible for establishing and
maintaining effective internal control
over financial reporting. In fulfilling
this responsibility, estimates and
judgments by management are required
to assess the expected benefits and
related costs of controls. A companys
internal control over financial reporting
is a process designed to provide
reasonable assurance regarding the
reliability of financial reporting and the
preparation of financial statements for
external purposes in accordance with
generally accepted accounting
principles. A companys internal control
over financial reporting includes those
policies and procedures that (1) pertain
to the maintenance of records that, in
reasonable detail, accurately and fairly
reflect the transactions and dispositions
of the assets of the company; (2) provide
reasonable assurance that transactions
are recorded as necessary to permit
preparation of financial statements in
accordance with generally accepted
accounting principles, and that receipts
and expenditures of the company are
being made only in accordance with
authorizations of management and
directors of the company; and (3)
provide reasonable assurance regarding
prevention or timely detection of
unauthorized acquisition, use or
disposition of a companys assets that
could have a material effect on the
financial statements.
Because of inherent limitations, internal
control over financial reporting may not
prevent or detect misstatements. Also,
projections of any evaluation of
effectiveness to future periods are
subject to the risk that controls may
become inadequate because of changes
in conditions, or that the degree of
compliance with the policies or
procedures may deteriorate.
A deficiency in internal control over
financial reporting exists when the
design or operation of a control does not
allow management or employees, in the
normal course of performing their
assigned functions, to prevent or detect
misstatements on a timely basis. A
material weakness is a deficiency, or
combination of deficiencies, in internal
control over financial reporting, such
that there is a reasonable possibility that
a material misstatement of the companys
annual or interim financial statements
will not be prevented or detected on a
timely basis.
Our consideration of the Funds internal
control over financial reporting was for
the limited purpose described in the first
paragraph and would not necessarily
disclose all deficiencies in internal
control that might be material
weaknesses under standards established
by the Public Company Accounting
Oversight Board (United States).
However, we noted no deficiencies in
the Funds internal control over financial
reporting and its operation, including
controls for safeguarding securities,
which we consider to be material
weaknesses, as defined above, as of
September 30, 2022.
This report is intended solely for the
information and use of management,
Shareholders and Board of Trustees of
Investment Managers Series Trust and
the Securities and Exchange
Commission, and is not intended to be
and should not be used by anyone other
than these specified parties.
/s/ Tait, Weller & Baker LLP
TAIT, WELLER & BAKER LLP
Philadelphia, Pennsylvania
November 29, 2022
taitweller.com
To The Shareholders and
Board of Trustees of
Investment Managers Series Trust
Page Two