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